HOUSEHOLD ACCESS TO RENEWABLE ENERGY AND ADVANCED COOKING

TECHNOLOGIES (HAREACT)

Environmental and Social Impact Assessment (ESIA) Study Report

Ministry of Energy and Water Resources (MoEWR)

September 2022

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DECLARATION

We, the undersigned, hereby declare that this ESIA Study Report represents the facts
pertaining to the Proposed Implementation of the Households Energy Access to Renewable
Energy and Advance Cooking Technology Project of the Federal Government of Somalia.

ON BEHALF OF MINISTRY OF ENERGY AND WATER RESOURCES

Name: Abdirizack Mohamed Muhumed,

Director General

Sign: ______________________________________________________

Dated: September 28th, 2022

DETAILS OF EXPERTS WHO CONDUCTED THE ESIA

1. Mr. Abdihamid Abdirahman Hassan,

Social Safeguard Specialist, MoEWR and
Sign: __________________ ____________

2. Mr. Abdullahi Ahmed Ali,

Environmental Specialist, MoEWR
Sign: ________________ ______________
 EXECUTIVE SUMMARY

This document contains Environmental and Social Impact Assessment (ESIA) and its commensurate
Environmental and Social Risks Management Plans (ESMP) for the project to be submitted to the African
Development Bank (AfDB) funded project titled ‘Households Access to Renewable Energy and advancing
cooking technologies project).

In accordance with the AfDB’s Environmental and Social Policy (ESP) regarding ESIAs, all proposed projects
activities shall undertake a screening of environmental and social risks and demonstrate compliance with
the environmental and social principles as outlined in the AfDBs operational safeguards. For project activities
that have the potential to cause environmental or social harm, an environmental and social assessment shall
be prepared, that identifies any environmental or social risks. According to the said AfDB’s operational
safeguards, the proposal should state the category in which the screening process has classified the project.
Projects activities likely to have significant adverse environmental or social impacts that are for example
diverse, widespread, or irreversible should be categorized as Category A projects. Projects with potential
adverse impacts that are less adverse than Category A projects, because for example they are fewer in
number, smaller in scale, less widespread, reversible, or easily mitigated should be categorized as Category
B. The projects with no adverse environmental or social impacts should be categorized as Category C.

According to the above AfDB’s classification system of projects and the incumbent screening process, the
interventions (activities) of this project have been classified as a “Category B” which imply that the proposed
interventions in the five project sites will have moderate risks or adverse impacts environmentally and
socially, thus not requiring full ESIAs. This is due to the fact that all of the construction activities and
installations of this project are not substantial and will be constructed or installed in government owned lands
and already built and operating facilities, which at the time of original construction have been subjected to
country’s and Bank’s ESIA regulations and supervision.

As all of the above sub-projects’ interventions fall as well under Category C according to the AfDB’s
classification ESIA Regulation’s classification with no significant environmental or social impacts that, if
existed, can be minimized or mitigated through the application of the Environmental and Social Risks
Management & Monitoring Plan (ESMMP) proposed.
Thus, this report has been developed in line with both the Government of Somalia (GoS) and AfDB’s
requirements, policies, and regulations. Hence, all proposed (concrete) project activities have been screened
against potential environmental and social risks and impacts. Where potential environmental and social
risks/impacts were identified, impacts have been assessed accordingly. An ESMP has been developed to
manage the potential risks (including avoiding and mitigating these risks with assignment of roles and
responsibilities).

The conclusion of this ESIA is that all potential environmental and social project risks are either minor to
moderate and can be mitigated through monitoring and best management practices articulated in the
ESMPs. No unidentified sub-project risks exist. However, if they were to arise due to unforeseen reasons or
conditions in the future through any significant proposed changes in the project during implementation, then
these shall be made available for effective and timely public consultation with directly affected communities
and assessed for impacts and mitigation measures accordingly including the option of conducting ad-hoc
standalone EISA case-by-case, if needed.

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Abbreviations

AfDB African Development Bank

ATMIS. African Union Transition Mission in Somalia
BESS Battery Energy Storage Systems
COVID-19 Corona Virus Disease 2019
DFID Department for International Development (UK)
EHS Environment, Health and Safety
ENEE Ente Nazionale Energia Elettrica (Somalia National Electric Corporation)
ESF Environmental and Social Framework
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESPs Electricity Service Providers
ESRES Energy Security and Resource Efficiency in Somaliland
ESS Environment and Social Standards
FGS Federal Government of Somalia
FMS. Federal Member States
GHG Green House Gas
GIIP General International Industrial Practices
GIS Geographical Information System
GNI Gross National Income
GRM Grievance Redress Mechanism
HSDGs High Speed Diesel Generators
LV Low Voltage
LMP Labor Management Plans
MoEWR. Ministry of Energy and Water Resources
MV Medium Voltage
NDP National Development Plan
NGOs Non-Government Organization
PAPs Project Affected Parties
PIU Project Implementing Unit
PSMP Power Sector Masterplan
RAP Resettlement Action Plan
RTK Real Time Kinetics
SDGs Sustainable Development Goals
SEP Stakeholder Engagement Plan
ESIA Environmental and Social Impacts Assessment
SMEs Small and Medium Enterprises
SRB Surveyor Registration Board

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Table of Contents
ABBREVIATIONS ............................................................................................................................................................... 3
1.0 INTRODUCTION .................................................................................................................................................... 6
1.1 PURPOSE OF THE ESIA ................................................................................................................................................. 6
1.2 LIMITATIONS OF THE STUDY........................................................................................................................................... 6
1.3 OUTLINE OF THE ESIA ................................................................................................................................................... 7
2.0 PROJECT DESCRIPTION ..................................................................................................................................... 7
2.1 PROJECT COMPONENTS ESTIMATED COST................................................................................................................... 9
2.2 PROJECT LOCATIONS .................................................................................................................................................. 10
2.3 PROJECT FINANCING PLAN: ........................................................................................................................................ 10
2.4 PROJECT BENEFITS:..................................................................................................................................................... 10
2.4.1 Expected Project Outcomes and Outputs: ........................................................................................................ 11
3.0 POLICY, LEGISLATIVE AND INSTITUTIONAL FRAMEWORKS .................................................................... 11
3.1 FEDERAL AND STATE REGULATION PERTAINING TO ESIA ........................................................................................ 11
3.1.1 The Federal Constitution: ..................................................................................................................................... 12
3.1.2 Federal Environmental Policies, Acts and Regulations ................................................................................... 12
3.1.3 Federal Social Policies, Acts and Regulations ................................................................................................. 13
3.1.4 Energy Policy and Regulations ........................................................................................................................... 13
3.2 AFDB ENVIRONMENTAL AND SOCIAL SAFEGUARDS.................................................................................................. 14
3.3 INTERNATIONAL CONVENTIONS SIGNED AND RATIFIED BY SOMALIA ........................................................................ 15
4.0 DESCRIPTION OF THE BASELINE CONDITIONS ........................................................................................... 18
4.1 PHYSICAL ENVIRONMENT ............................................................................................................................................. 18
4.1.1 Climate .................................................................................................................................................................... 18
4.1.2 Topography ............................................................................................................................................................ 18
4.1.3 Geology and Soils ................................................................................................................................................. 19
4.1.4 Water Resources and Hydrology: ....................................................................................................................... 21
4.1.5 Land Use ................................................................................................................................................................ 21
4.2 BIOLOGICAL ENVIRONMENT ......................................................................................................................................... 22
4.2.1 Land Cover and Vegetation ................................................................................................................................. 22
4.2.2 Fauna ...................................................................................................................................................................... 23
4.3 SOCIO-ECONOMIC ENVIRONMENT AND POPULATION.................................................................................................. 23
4.3.1 Economy and Poverty........................................................................................................................................... 23
4.3.2 Governance and Security ..................................................................................................................................... 24
4.3.3 Gender .................................................................................................................................................................... 24
4.3.4 Access to Education and Health Facilities ........................................................................................................ 24
4.3.5 Land Use and Settlement Patterns..................................................................................................................... 25
4.3.6 Economic Activities ............................................................................................................................................... 25
4.3.7 Waste Management .............................................................................................................................................. 25
4.3.8 Youth as a Vulnerable Group .............................................................................................................................. 26
4.3.9 Clan Dynamics and Minority Groups .................................................................................................................. 26
5.0 STAKEHOLDER CONSULTATIONS.................................................................................................................. 27
6.0 ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES ............................................... 30
6.1 POTENTIAL POSITIVE IMPACTS OF THE PROJECT ........................................................................................................ 32
6.1.1 Reduced CO2 and air emissions ........................................................................................................................ 32
6.1.2 Development of Somalia’s renewable energy infrastructure .......................................................................... 32
6.1.3 Improved efficiency of off-takers operations ..................................................................................................... 32
6.1.4 Creation of employment opportunities ............................................................................................................... 32
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 6.1.5 Increased government revenue generation ...................................................................................................... 33
6.2 POTENTIAL NEGATIVE IMPACTS OF THE PROJECT AND MITIGATION MEASURES ....................................................... 33
6.2.1 Air quality - Construction phase .......................................................................................................................... 33
6.2.2 Air quality - Operation phase ............................................................................................................................... 33
6.3 MITIGATION MEASURES ............................................................................................................................................... 33
6.3.1 Waste ...................................................................................................................................................................... 34
6.3.2 Noise: Construction phase ................................................................................................................................... 35
6.3.3 Soil Quality ............................................................................................................................................................. 35
6.3.4 Water Resources, Water Quality and Wastewater........................................................................................... 36
OPERATION PHASE:..................................................................................................................................................................... 37
6.3.5 Biological Environment ......................................................................................................................................... 37
6.3.6 Municipal Services ................................................................................................................................................ 37
6.3.7 Community Health and Safety............................................................................................................................. 38
6.3.8 Workplace Health and Safety .............................................................................................................................. 39
6.4 CULTURAL HERITAGE AND ARCHAEOLOGICAL FEATURES........................................................................................... 39
7.0 DESCRIPTION OF ALTERNATIVES SCENARIOS CONSIDERED ................................................................. 53
7.1 NO DEVELOPMENT ........................................................................................................................................................ 53
7.2 ALTERNATIVE SITE LOCATION ...................................................................................................................................... 54
7.3 ALTERNATIVE TECHNOLOGY ........................................................................................................................................ 54
8.0 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP) ................................................................. 54
8.1 INSTITUTIONAL ARRANGEMENTS ................................................................................................................................. 55
8.1.1 Monitoring and Reporting ..................................................................................................................................... 55
8.2 SUMMARY OF THE ESMP FOR CONSTRUCTION AND OPERATION PHASES ............................................................... 56
8.3 E&S MANAGEMENT PLANS FOR SPECIFIC ASPECTS OF THE PROJECT...................................................................... 66
8.3.1 Occupational Health and Safety Plan ................................................................................................................ 66
8.3.2 Environmental and Waste Management Plan .................................................................................................. 67
8.3.3 Emergency Preparedness and Response Plan................................................................................................ 67
8.3.4 Security Risk Management Plan ......................................................................................................................... 68
8.3.5 Decommissioning Plan ......................................................................................................................................... 68
8.3.6 Human Resources Policy ..................................................................................................................................... 69
8.3.7 Working conditions and terms of employment .................................................................................................. 69
8.3.8 Non-discrimination and harassment ................................................................................................................... 69
8.3.9 Stakeholder Engagement Plan and Grievance Redress Mechanism ........................................................... 70
8.3.10 Grievance Redress Mechanism ..................................................................................................................... 71
9.0 CONCLUSION AND RECOMMENDATIONS: .................................................................................................... 74
9.1 CONCLUSIONS .............................................................................................................................................................. 74
9.2 RECOMMENDATIONS .................................................................................................................................................... 75
10.0 REFERENCES ..................................................................................................................................................... 76
11.0 ANNEXES ............................................................................................................................................................. 76
11.1 ANNEX: STAKEHOLDER CONSULTATIONS RESPORT ................................................................................................. 76

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 1.0 INTRODUCTION

The Federal Government of Somalia (FGS) is implementing Households Access to Renewable Energy
and advancing cooking technologies project with a grant funding from African Development Bank (AfDB).
The project objective is to provide off grid electricity access and dissemination of advanced cooking
technologies to and Urban & Rural communities to benefit population access to modern electricity supply
and advanced cooking technologies as well as contributes to economic growth, reduction of the
environmental impact and health condition due to in efficient use of biomass.

Somalia’s government has prioritized the recovery of its energy and electricity infrastructure as a crucial
enabler of economic development and poverty reduction, as is outlined in its ninth National Development
Plan for 2020-2024. After a prolonged period of conflict and state collapse, Somalia’s energy sector is
inefficient and existing installed capacity is not sufficient to meet current and future demand. Power is
provided by private energy service providers who predominately operated diesel-powered mini grids. This
has resulted in a very expensive and inefficient power supply—with electricity prices that are among the
highest in the world which impedes access to electricity for Somalis and is constraint to economic growth.
On the other hand, the draughts have become cyclical in Somalia for the last two decades due to
environmental degradation during the civil war. Just recently, the president of Somalia established a whole
ministry for environment and climate change cementing government’s commitment to tackle the
environmental degradation and the resultant climate changes effects.

This project aims to: (i) increase access to electricity by using off grid electricity supply systems (Solar &
Battery storage systems, Solar home systems (SHS), Wind etc. (ii) Dissemination of advanced cooking
technologies for rural communities, and (iii) strengthen the capacity of the Ministry of Energy & Water
resources in design and utilization of modern renewable energy resources particularly of Solar, wind, storage
systems, hybrid systems etc. and advanced cooking technologies.

1.1 Purpose of the ESIA

The overall objective of the ESIA study is to ensure that potential environmental and social impacts
associated with development of the project are identified, assessed, and managed appropriately to meet the
compliance requirement of the Federal Government of Somalia (FGS) and the African Development Bank
(AfDB). Mitigation measures are then developed and incorporated into the project to eliminate, minimize, or
reduce adverse impacts and, where practicable, to enhance benefits.
The specific objectives are:
i. To prepare a detailed environmental and social baseline situation.
ii. To predict and evaluate possible environmental and socio-economic impacts
iii. To delineate Environmental and Social Management Plan and Monitoring Plan.

1.2 Limitations of the Study

The impact assessment study for the proposed Project is largely based on the Project information from client,
discussion with local community and other stakeholders and observations from various surveys and
investigations undertaken in the Project area. Professional judgement and subjective interpretation of facts
has been applied for this study. Any change in Project location, orientation, proposed Project activities is
likely to result in variation of the impacts. It is to be noted that any technological advances during
implementation of the Project will alter the extent and severity of impacts on the surroundings.

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The statements, conclusions, and opinions contained in the study will only be intended to give
approximations of the environmental and social condition of the project sites. Moreover, there are several
major limitations that are inherent in the conduct of this, or any other, environmental, and social assessment.
• First, it is difficult to predict which, if any of the potential environmental and social issues identified
will become actual problems in the future, environmental regulations continually change, as do the
enforcement priorities of the applicable governmental agencies involved.

• Second, even for problems currently identified, it is often difficult and sometimes impossible to
accurately estimate the liabilities that may be involved in mitigating the problem(s), for the legal and
technological standards for evaluating, mitigating, and allocating liability for environmental and social
issues are in a constant state of change. Moreover, the liability for mitigating environmental problems
tends to be highly dependent upon agency negotiations and the sometimes arbitrary and
unpredictable nature of agency officials charged with such negotiations.

• The data collection has been carried out during COVID-19 pandemic and under tight schedule. Team
mobilization, field visit, consultations and group discussion are very difficult to arrange as this study
will be done in just a month.

1.3 Outline of the ESIA

This report is structured as follows:

Section 1 – Introduction: background and an overview of the proposed project, purpose and scope of the
ESIA.

Section 2 – Project Description: including the site location, project components and design, and the
requirements during construction and operation.

Section 3 – Policy and Legal Framework: review of the legal and regulatory framework and the IFC
Performance Standards applicable to the project activities.

Section 4 – Environmental and Social Baseline: describes the physical and biological environment, and
socio-economic conditions in the project area.

Section 5 – Stakeholder Engagement: describes the stakeholder consultations, findings, and ongoing
stakeholder engagement process.

Section 6 – Environmental Impact Assessment and Mitigation: discusses the potential impacts from project
activities during construction and operation and their mitigation measures.

Section 7 – Analysis of Alternatives: discussion of alternatives for different project components.

Section 8 – Environmental and Social Management Plan: provides the E&S management measures and
monitoring plan for the project.

2.0 PROJECT DESCRIPTION

The project consists of six components as detailed below.

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Component 1- Power Generation Expansion (expand existing generation through establishment of solar PV
and Battery Energy Storage Systems-BESS) in selected five locations (towns) namely Eyl, Dusamareeb,
Jowhar, Barawe, and Bardhere with a total PV Solar capacity of 2,450 kWp and 4,750 kWh energy storage
system (BESS).

Component 2- Expansion of Distribution Network and Customer Connections:

Subcomponent 2.1: Construction of MV & LV distribution lines and installation of distribution

transformers and the selected five locations with a total scope of 30.22km of new 11kV overhead
lines, installation of 31x50 kVA 11/0.4 kV pole mounted distribution transformers and installation of
24km of low voltage overhead lines.

Subcomponent 2.2- Electricity Connection Expansion (Customers connections): Purchase of

postpaid energy meters to enhance connection of new customers and to help ease connection of
new customers particularly the poor and vulnerable people who cannot afford the new connection
cost in the targeted areas.

Component 3- Dissemination of Advanced Cooking Technologies: The Clean Cooking and Improved
Biomass Cook stoves will help in enhancing efficiency of utilization of charcoal and wood fuel, reduce the
impact on health and carbon emissions. Planned to disseminate 25,000 units of advanced cook stoves in
the targeted areas.

Component 4 TA & Capacity Building and Design & Supervision Consultant: Under talking TA & Capacity
building for the Federal Ministry of Energy and Water resources, Federal Member states and private sector
on development, integration, and utilization including Operation and maintenance of renewable energy
technologies (on grid, off grid systems etc.) and clean advanced cooking technologies. And consultancy
service for project design (design and tender document preparation), management and supervision.

Component 5- Project management operational cost for the PIU to cover the project management and
operational expenses in related to the project implementation.

Component 6- Implementation of ARAP & ESMP: implementation of resettlement action plan &
compensation and ESMP.

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Figure 1:1: Project Sites

2.1 Project Components Estimated Cost

Component Estimated Cost (UA) Estimated Cost (USD)

Foreign Local Total Foreign Local Total
Component-I 2,074,059.23 518,514.81 2,592,574.04 2,898,000.00 724,500.00 3,622,500.00
Component-II 705,822.54 176,455.63 882,278.17 986,217.60 246,554.40 1,232,772.00
Component-III 120,235.32 - 120,235.32 168,000.00 - 168,000.00
Component-IV 715,686.41 - 715,686.41 1,000,000.00 - 1,000,000.00
Component-V 858,823.70 214,705.92 1,073,529.62 1,200,000.00 300,000.00 1,500,000.00

Component-VI - 250,000.00 250,000.00 - 349,315.00 349,315.00

1,271,054.4
Total 4,474,627.20 909,676.37 5,634,303.57 6,252,217.60 7,872,587.00
0
Government1
Counterpart - 700,000.00 700,000.00 978,082.00 978,082.00
contribution
1,609,676.3 2,249,136.4
Grand Total 4,474,627.20 6,334,303.57 6,252,217.60 8,850,669.00
7 0

1
The ARAP, Compensation and ESMP implementation cost will be confirmed after completion of the E&S
studies
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 2.2 Project Locations

The proposed PV Solar mini-grids and distribution lines sites are located in 5 regions of Somalia, among
them, Eyl (Puntland), Dusamareeb (Galmudug); Jowhar (Hirshabelle), Barawe (South-West) and Bardhere
(Jubbaland). Projects include PV Solar Mini-grid 2,450 kWp capacity and Battery Energy storage system
(BESS) with energy rating of 4,750 kWh, and 54.22 kilometers (km) Medium and Low Voltage distribution
lines reticulations and installation of 31 pole mounted distribution transformers 11/0.4 kV 50 KVA rating in
the targeted l areas.

Table 3.1 Proposed Generation & Storage system

No. Project sites Solar PV System Battery Energy Storage
(kW) System (kWH)
1 Eyl 250 750
2 Dusamareeb 500 1,000
3 Jowhar 600 1,000
4 Barawe 550 1,000
5 Bardhere 550 1,000
Total 2450 4750

Table 3.2 Power Distribution Expansion

No. Description of network
New 11kV New Low Voltage 50kVA 11/0.4kV
Project sites Overhead Lines Overhead Lines Transformers (Number)
(km) (km)

1 Eyl 5.82 24.0 3

2 Dusamareeb 8.4 8
3 Jowhar 6.93 7
4 Barawe 4.07 3
5 Bardhere 5.0 10
Total 30.22 31

2.3 Project Financing Plan:

The total project cost is estimated to be UA 6.084 million (USD 8.501 million) and the AfDB covers the cost
of infrastructure and consultancy services in the amount of UA 5.384 million (USD 7.523 million) which is
85% of the total cost and Government of Somalia covers the cost of implementation of the ARAP & ESMP
in the amount of UA 0.7 million (USD 0.978 million) which is 15% of the total cost as counterpart funding.

2.4 Project Benefits:

The project will cover the Eyl, Dusamareeb, Jowhar, Barawe and Bardhere. The main socio-economic impact
of the proposed project is the utilization of off-grid systems to increase electricity access and improve efficient
use of biomass/fossil fuels for cooking throughout the country and particularly of the rural areas. This will
contribute to improving economic growth, the living conditions and health for the population and reduction of
environmental degradation.

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 2.4.1 Expected Project Outcomes and Outputs:
Development outcomes:

• Increased share of the clean renewable energy mix above the total generation and
affordable electricity to all type of consumers

• Improved access to electricity and advanced cooking technologies to rural and urban
population

Key performance indicators (Out puts):

- Number of constructed PV Solar & BESS system (Generation):

- Constructed distribution (MV & LV) network in the targeted areas (kms):

- Number of new households connected because of this intervention of which - % will be women
headed households

- Number of disseminated advanced cooking technologies (advanced charcoal and biomass/wood

cooking stoves) and of which __ number will be vulnerable people

- Number of trained MoEWR and private sector staff on development, integration, and utilization
including operation and maintenance of renewable energy technologies (on grid, off grid systems
etc.) and Ministry staff on the preparation of E&S safeguard documents, monitoring and follow-up
of the energy infrastructure projects

- Created job opportunities (Temporary & permanent):

- CO2 emission reduction:

3.0 POLICY, LEGISLATIVE AND INSTITUTIONAL FRAMEWORKS

This section summarizes the E&S legislation and regulations pertaining to the project. First, it considers
Somalia’s federal policy and law pertaining directly to the ESIA and of broader relevance to the project.
Second, it analyzes international standards and best practices that are relevant to the project, focusing
specifically on the how the The AfDB Environmental and Social Safeguards Policies apply to the project.

3.1.1 Federal and State Regulation Pertaining to ESIA

In all Somali (Somalia and Somaliland) territories policy and legislation with respect to the environment and
social is nascent, in terms of assessing the potential impact of such policies on the environment and social,
or how they could contribute to environmental conservation and sustainable livelihood improvement.

Several international agreements and Multilateral Environment Agreements (MEAs) exist, and although
binding on Somalia and Somaliland there has been little progress in implementation due to the chronic
conflict.

In recent years Somalia and Somali territories have effected constitutional changes that define natural
resources, common environmental goods and ecosystem services as protectable public assets and
ascertain the right to a clean and healthy environment.
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3.1.2 The Federal Constitution:

Somalia’s current constitution addresses the management of the environment. Particularly articles recognize
the followings:

1) Article 24 guarantees fair labor relation and provides protection against abuse of environment.
2) Article 25 states that “[every Somali] has the right to an environment that is not harmful to their health and
well-being, and to be protected from pollution and harmful materials.” Further indicating “[every Somali] has
the right to have a share of the natural resources of the country, whilst being protected from excessive and
damaging exploitation of these natural resources.”

3) The right to own property and the right to compensation is addressed in Sections 1 and 2 of Article 26
which state:
a) Every person has the right to own, use, enjoy, sell, and transfer property.
b) The state may compulsorily acquire property only if doing so is in the public interest.
c) Any person whose property has been acquired in the name of public interest has the right to just
compensation from the State as agreed by the parties or decided by a court

4) Article 43 provides guidelines for policy development designed to ensure “land is utilized without causing
harm to the land”
5) Article 45 highlights the government’s responsibility in prioritizing “… the protection, conservation, and
preservation of the environment against anything that may cause harm to natural biodiversity and the
ecosystem.” This article also mentions the duty of the people “… to safeguard and enhance the environment
and participate in the development, execution, management, conservation and protection of the natural
resources and environment.”

The specific laws that contain aspects which provide social and environmental protection include:

a. Law No. 65 of 18 October 1972 to promulgate the Labour Code.

b. Somali Fisheries Law (Law No. 23 of November 30, 1985)
c. Somali national Water Law of 11 November 2017

3.1.3 Federal Environmental Policies, Acts and Regulations

The Federal policies, laws and regulations guiding ESIAs and providing a comprehensive framework for
environmental management have yet to be fully adopted. So far, the FGS has developed a National
Environmental Management Policy (2020), National Climate Change Policy (2020), Draft National Charcoal
Policy (2022), Draft National Forest Management Policy, and Draft Ozone Layer Protection Regulation
(2021). In addition to that, there are other sectoral policies, acts and regulations relevant to the labour, water,
livestock, agriculture, petroleum, fish and marine resource sectors.
This was the first time environmental policy that has been endorsed since the formation of Somalia’s federal
institutions. The National Environmental Bill has been drafted and was approved by the Cabinet on
November 26, 2020. The Bill, based on 25 and Article 45 of the Provisional Constitution, will be moved to
the two houses of parliament for approval. The Bill has 18 sections and has clauses relevant to this project.
The next step is for the Parliament to endorse it and then signed by the President to mark its official adoption
as national legal framework. Unfortunately, there is no clear timeline to finalize this process, however
estimations indicate that; it may take for a period of one year.

At the Federal level, previously and until recently; the Directorate of the Environment and Climate Change
(DoECC) within the Office of the Prime Minister was mandated to draft the national environmental policies,
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regulations and laws including establishing Environmental Quality Standards, Sectoral Environmental
Assessments, Environmental Impact Assessments and Environmental Audits. The new government of
Somalia has established a fully-fledged Ministry of Environment and Climate Change which now lead all the
environment and climate change related mandates and responsibilities.

At Federal Member States level, State level laws and regulation are slightly advanced for some states and
regions like Puntland and Somaliland, while in others like South-West State, Hirshabelle, Galmudug and
Jubbaland do not have any significant legislative frameworks governing the management of the environment
and natural resources sector in place. Other than the pieces of legislation available in some states as
discussed below

3.1.4 Federal Social Policies, Acts and Regulations

On a similar note, the Ministry of Labor and Social Affairs has developed a number of policies and strategies
necessary for employment, labor protection and social protection. Despite that, it is noted that Legislation on
occupational safety and health (OSH) in Somalia is limited, with the labour code known as Act No. 31 of
2004: Private Sector Act as the main reference on occupational safety and health issues. The Labour Code
establishes the rights, duties and responsibilities of the parties of labour relations, as well as conditions for
ensuring the safety and health of workers.

On the other hand, the Somalia’s National Gender Policy (2016) has been approved by the Federal Council
of Ministers. The goal of the policy is to promote gender equality and sustainable human development in
Somalia by ensuring that equal value is placed on the contributions of women and men as equal partners in
the areas of economic empowerment, education, health, and political transformation. It is intended to guide
further policy, legislation and programmed to promote equal opportunities for men and women in all spheres
of life and sets out gender priorities in the areas of health, education, economic empowerment, political
participation. The policy identifies creating economic opportunities for both men and women, especially to
improve the economic status of men and women in rural areas, as a priority. This includes prioritizing the
establishment of vocational, entrepreneurs and skills enhancement programs and training for women and
men, including those with disabilities, among other areas.

The federal legal framework for addressing GBV is under review. The FGS has drafted the Sexual Offenses
Bill (2017) with support from the UN, which has been tabled with the Parliament and is still under review.
The pre-existing Penal Code (1962) includes some provisions relevant to addressing GBV, including
criminalizing rape, but it does not provide an adequate legal framework for dealing with GBV cases 2.

3.2 Energy Policy and Regulations

The Ministry of Energy and Water Resources at the federal level has the responsibility to oversee
operations in the energy sector. The FGS has prioritized the development of an energy policy (2018),
strategy, and regulatory framework, in line with the NPD-9 and the Power Master Plan (2018), and several
policies and laws are currently under development notable the Federal Electricity Bill and regulation.

The policy goal of the National Energy Policy is to provide adequate, affordable and sustainable access
to efficient energy to the Somali society, with commitment to environmental stewardship, while also
improving quality of life, promoting socio-economic growth, developing clear policies, regulations, building
strong institutions, and unlocking the country’s renewable energy potential.

2
In practice, most GBV cases are dealt with by the customary system

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Outside the sphere of the federal government each federal member state has a ministry of energy
responsible for regulatory matters and has the mandate to implement energy-related initiatives, but has
limited power to pass new regulations and laws.

Overall, the renewable energy sector lacks specific policies and regulations, Renewable energy is highly
valuable to the nation and requires adequate policies, investment, capacity building, technology transfer
and incentive schemes to promote the integration of rural electrification and the use of off-grid and mini-grid
systems.

3.3 AfDB Environmental and Social Safeguards

In December 2013 AfDB published its Integrated Safeguards System (ISS), which is a cornerstone of its
strategy to promote growth that is socially inclusive and environmentally sustainable. AFDB safeguards are
powerful tools for identifying risks, reducing development costs, and improving project sustainability, thus
benefiting affected communities and helping to preserve the environment. The ISS builds on the two previous
safeguard policies i.e. Involuntary Resettlement (2003) and Environment (2004) and on three cross cutting
policies and strategies: Gender (2001), the Climate Risk Management and Adaptation Strategy (2009) and
the Civil Society Engagement Framework (2012). It also builds on the Bank’s sector policies: Health (1996),
Integrated Water Resources Management (2000), Agriculture and Rural Development (2000, 2010), and
Poverty Reduction (2004).

The safeguards aim to:

o Avoid adverse impacts of projects on the environment and affected people, while maximizing potential
development benefits to the extent possible.
o Minimize, mitigate, and/or compensate for adverse impacts on the environment and affected people when
avoidance is not possible; and
o Help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage
environmental and social risks. Table 6 below provides the requirements of the AfDB in reference to the
ISS and their relevance.

Table 2.0
Operational Safeguard Reviewed Relevancy

Operational Safeguard This overarching safeguard governs the process of

1: Environmental and ✓ determining a project’s environmental and social category and
Social Assessment the resulting environmental and social assessment
requirements. This ES and ESMP have been prepared in
fulfillment of this requirement.

Operational Safeguard This safeguard consolidates the policy commitments and

2: Involuntary ✓ requirements, set out in the Bank’s policy on involuntary
Resettlement Land resettlement, and incorporates several refinements designed
Acquisition, Population, to improve the operational effectiveness of those
Displacement and requirements. An ARAP has been prepared in fulfillment of this
Compensation

14
 requirement. Only compensation of trees and crops is
anticipated and no displacement of people.

Operational Safeguard This safeguard aims to conserve biological diversity and

3: Biodiversity and ✓ promote the sustainable use of natural resources. It also
Ecosystem Services translates the commitments in the Bank’s policy on integrated
water resources management into operational requirements.
Adverse impacts were assessed to be minor and negligible
due to project activities.

Operational Safeguard Safeguard covers the range of key impacts of pollution, waste,
4: Pollution Prevention ✓ and hazardous materials for which there are agreed
and, Control, Hazardous international conventions, as well as comprehensive industry
Materials and Resource specific and regional standards, including greenhouse gas
Efficiency accounting, that other multilateral development banks follow.
Adverse impacts were assessed to be minor and negligible
due to project activities.

Operational Safeguard This safeguard establishes the Bank’s requirements for its
5: Labor Conditions, ✓ borrowers or clients concerning workers’ conditions, rights and
Health and Safety protection from abuse or exploitation. An ESMP has been
prepared and management options provided to ensure good
working conditions, workers’ organizations, occupational
health and safety, and avoidance of child or forced labor.

3.4 International Conventions Signed and Ratified by Somalia

Table 3-1: International Conventions/Treaties In Relation To Environmental & Social Safeguards Standards
The Somalia Has Ratified/Signatory

Convention /Treaty Date Relevance

Ratified/Signed
Environment Agreements and Conventions
The 1992 United 2009 The primary purpose of the Convention is to establish
Nations Framework methods to minimize global warming and in particular the
Convention on Climate emission of greenhouse gases. The Convention was
Change adopted in 1992 and came into force in 1994.
United Nations September The Convention has three main goals including which are,
Convention on 2009 the conservation of biological diversity (or biodiversity); the
Biological Diversity sustainable use of its components; and the fair and
(1992). equitable sharing of benefits arising from genetic
resources.
Convention on 1986 The convention aims to protect endangered plants and
International Trade animals.
Against Endangered
Species (CITES).
15
Convention /Treaty Date Relevance
Ratified/Signed
Vienna Convention on 2001 The Vienna Convention was an intergovernmental
the Protection of the negotiation for an international agreement to phase out
Ozone Layer March ozone depleting substance. The Convention encourages
1985 intergovernmental cooperation on research, systematic
observation of the ozone layer, monitoring of CFC
production, and the exchange of information.
United Nations 2002 The Convention combats desertification in those countries
Convention to Combat that experience serious droughts and/or desertification.
Desertification (2002).
Basel Convention July 2010 The overall goal of the Basel Convention is to protect
human health and the environment against the adverse
effects that may result from the generation, trans boundary
movements and management of hazardous and other
wastes.
Stockholm Convention July 2010 The Stockholm Convention is a global treaty that aims to
protect human health and the environment from the effects
of persistent organic pollutants (POPs). The Convention
entered into force on May 17, 2004.
Social Related Agreement and Convention
The Freedom of March 22, 2014 Article 3 (1) Workers' and employers' organizations shall
Association and have the right to draw up their constitutions and rules, to
Protection of the Right elect their representatives in full freedom, to organize their
to Organize administration and activities and to formulate their
Convention (1948) No programs.
87 (2). The public authorities shall refrain from any
interference, which would restrict this right or impede the
lawful exercise thereof.
Article 5 Workers' and employers' organizations shall have
the right to establish and join federations and
confederations and any such organization, federation or
confederation shall have the right to affiliate with
international organizations of workers and employers.
The Right to Organize March 20, 2014 Article 1 Each Member which ratifies this Convention shall
and Collective take immediate and effective measures to secure the
Bargaining prohibition and elimination of the worst forms of child labour
Convention, 1949 (No. as a matter of urgency.
98) Article 2 For the purposes of this Convention, the term child
shall apply to all persons under the age of 18.
Convention Nov 18th, Article I 1. Each Member of the International Labour
concerning Forced or 1960. Organization, which ratifies this Convention, undertakes to
Compulsory Labour suppress the use of forced or compulsory labour in all its
(ILO No. 29) forms within the shortest possible period.
Article 5 1. No concession granted to private individuals,
companies or associations shall involve any form of forced
or compulsory labour for the production or the collection of
products which such private individuals, companies or
associations utilize or in which they trade

16
Convention /Treaty Date Relevance
Ratified/Signed
Convention on the 2015 The Convention on the Rights of the Child is the most
Rights of the Child, comprehensive compilation of international legal standards
1989. for the protection of the human rights of children. It
acknowledges children as individuals with rights and
responsibilities according to their age and development, as
well as members of a family or community. This includes
non-discrimination, the best interest of the child, the right to
life, survival and development and the right to participation.
Constitution of the 1960 The constitutional principle is that universal and lasting
International Labor peace can be established if it is based on social justice. The
Organization: ILO has generated such hallmarks of industrial society as
the eight-hour work day, maternity protection, child labor
laws, and a range of other principles.
ILO Convention 182 2014 Ratification of this Convention makes a country commit
on Worst Forms of itself to taking immediate action to prohibit and eliminate the
Child Labor. worst forms of child labor. Some predefined worst forms of
child labor include sale of a child, trafficking of children,
forced or compulsory labor, commercial exploitation of
children, prostitution or the production of pornography, and
work by its nature that is likely to harm the health, safety
and morals of children.
UN Convention on the 2015 The Convention is a Human Rights treaty that sets out the
Rights of the Child. civil, political, economic, social, health and cultural rights of
children. It defines a child as any human being under the
age of 18 unless the age of majority is attained earlier under
national legislation.
Convention on the Not yet The CEDAW affirms that gender equality is a precursor for
Elimination of All forms development and peace. It establishes legal standards for
of Discrimination the attainment of gender equality through the elimination of
against Women discrimination against women in all aspects of political,
(CEDAW 1981): social, economic and cultural life. It highlights the
importance of equality and equal opportunity in political and
public life as well as education, health and employment.
Ratifying Governments are required to set in place
measures to enable and expedite gender equality in law
and fact as well as confronting the underlying social political
inequalities that perpetrate asymmetrical power relations
based on gender.
Rotterdam Convention Effectiveness The purpose is to promote shared responsibilities in relation
in 2004 to importation of hazardous chemicals. The convention
promotes open exchange of information and calls on
exporters of hazardous chemicals to use proper labelling,
include directions on safe handling, and inform purchasers
of any known restrictions or bans. Signatory nations can
decide whether to allow or ban the importation of chemicals
listed in the treaty, and exporting countries are obliged to
make sure that producers within their jurisdiction comply.
Some types of asbestos are listed as banned under this
treaty but Chrysotile asbestos is not yet banned though
17
 Convention /Treaty Date Relevance
Ratified/Signed
there is global discussions to include it on the listed
chemicals. Somalia acceded the Convention in 2010.
Maputo Protocol Not ratified Protocol to the African Charter on Human and People´s
Rights on the Rights of women in Africa. Somalia has
signed but the Protocol.

4.0 DESCRIPTION OF THE BASELINE CONDITIONS

This section describes the overall baseline condition of Somalia in terms of biophysical environment, as well
as the socio-economic background. The baseline conditions obtaining in the three affected states of Somalia
mentioned are principally similar to those generally obtaining in Somalia as a nation, except for minor
variations.

4.1 Physical Environment

Somalia is in the Horn of Africa where it lies between latitudes 2°S and 12°N, and longitudes 41° and 52°E.
The country is bordered by Djibouti to the northwest, Kenya to the southwest, the Gulf of Aden to the north,
Indian Ocean to the east, and Ethiopia to the west. Somalia has an area of 637,655 km². The country
stretches for almost 1,550 km from north to south between latitudes 12o00’N and 1o37’S, and 1,095 km
from west to east between longitudes 41o00’ and 51o21’E

4.2 Climate

Somalia is a large, relatively flat country, with an arid or semi-arid climate and prone to severe droughts and
floods. Its twelve million or so people mostly support themselves through nomadic pastoralism and
agriculture. They are among the poorest in the world, and although too few data are available to allow the
country to be ranked relative to others according to the Human Development Index (HDI), it is believed to
score very poorly on all HDI indicators.

As alluded to earlier, Somalia has a warm desert climate in the north and a semi-arid climate in the south.
The country is characterized by four seasons: between the two monsoons, there are irregular rain and hot
and humid periods. From April to June, there is the main rainy season, Gu. This is followed by the dry Xagaa
season before the Dayr provides further rainfalls from October to December, with approximately 500 mm
rainfall annually in the northern highlands, 50-150mm along coast, and 300-500 mm in the southwest. The
annual cycle is completed as the dry Jilaal season stretches from December to March.

The climate in the Horn of Africa is affected by the Indian Ocean’s variable sea-surface temperatures and
the El Niño–Southern Oscillation (ENSO) cycle3. Different ENSO phases have diverse impacts during
seasons and across different parts of the Horn4. The country experiences droughts every 2 to 3 years mostly
followed by devastating floods.

4.2.1 Topography

Somalia’s terrain is mostly flat. The Guban plains that parallel the Gulf of Aden coast rise inward towards the
rugged Karkaar mountain ranges whose elevation is between 1,800 meters and 2,407 metres above sea at
Shimber Berris, the country’s highest point5. Southward the mountains descend to the Ogo, an elevated

3Williams and Funk 2011, pp. 2417–35.

4Anyah, and Semazzi, 2006, pp. 39–62.

18
plateau of broken mountain terrain and shallow plateau valleys. The Ogo gradually slopes toward the Indian
Ocean and in central Somalia constitutes the Mudug Plain. At the eastern part of the plateau lies the
Nugaal valley which has extensive network of intermittent seasonal watercourses. The western part of the
Ogo slopes gently southward and gradually merges into the Haud region.

4.2.2 Geology and Soils

Key formations in Somalia include alluvium from the Pleistocene to Holocene period whose general
characteristic show Older Pleistocene alluvial sediments and recent alluvium including sandy clay with
lenses of sand and fine gravel to coarse gravels and boulders.

Figure 2:2: Geology and Soils of Somalia

In some parts are fine sands forming dunes and red soils and calcerites. Quaternary unconsolidated
sediments are mostly found in the southern coast and the riverine areas of Southern Somalia. The
Northeastern part, in which Eyl lied, of the country is dominated by terciary sedimentary from the Eocene
period. On the Southern side of this Jowhar formations consisting of gypsum, marls and dolomites. The rest
of the country is made up Gypsisols. From Jowhar to Barawe the soil types are mixed consisting of Leptosols
Calsisols, and Gypsisols. Bardhere has a mixture of Fluvisols, Calcisols, Arenosols and Leptosols. From,
Eyl to Marko lies on top of Gypsisols, Solonchaks and Regosols (Figure 26).

19
Figure 2:3: Soils of Somalia

20
4.2.3 Water Resources and Hydrology:

Rivers Juba and Shabele are the main sources of surface water in Somalia. These two perennial rivers
originate from the Ethiopian highlands in the north and flow southwards towards the Indian Ocean.
The Juba-Shabelle basin, has a total area of 810 427 billion square meters, of which one third each is
in Ethiopia, Kenya, and Somalia.

Figure 2:4: Somalia’s Main Aquifers (BGS, 2018)

The mean annual runoff at the border between Ethiopia and Somalia is 5.9 BCM for the Juba River at
Bardhere and 2.3 BCM for the Shabelle River at Jowhar (AfDB, 2010 & FAO, 2005). Jowhar and
Bardhere are riverine towns.

4.2.4 Land Use

In Somalia, rangelands are estimated to be about 80 per cent of the nation’s land area (AfDB, 2010).
Bardhere and Jowhar land is used for grazing and for farming around the river. It is the same case for
the project sites which lie on the coastline Barwe and Eyl the rest of the land across the project
locations is used for grazing. Between the main towns where trade occurs there are several villages
and small towns that serve the nomadic communities and travelers.

21
 4.3 Biological Environment

4.3.1 Land Cover and Vegetation

About 2% of Somalia’s total land cover is considered as arable land, and of this 18.7% is appropriate
for irrigated agriculture (IUCN 1997). Figure 28 shows the land cover in Somalia. In Southern Somalia
particularly, the riverine areas of Kismayo there are some mangrove and acacias which are dwindling
at a high rate due to over exploitation from charcoal trade. In Eyl, the land is mostly covered by various
local shrubs and some areas that can be described as grassland. The Bardhere, Jowhar sites are
dominated by acacia with broad canopy and palm trees. Dhusomareb, Eyl and Barawe , the land
cover is dominated by shrubs.

Figure 2:4: Somalia land Cover from satellite images

Eyl Grassland and Shrubland ecoregion consists of white and orange sand dunes dominated by
perennial dune grasslands and sedges. This region also supports six endemic species of birds,
mammals, and reptiles. This ecoregion is a long, narrow coastal strip from just south of Mogadishu to
some 250 km north of Eyl. It is a low-lying area of coastal plain with dunes of white and orange sand
and associated dune grassland. The dunes reach a maximum height of 60 m, and the dune field is
about 10 to 15 km wide along its entire length. Inland, the habitat changes to dry savanna and semi-
desert vegetation.

22
4.3.2 Fauna

Somalis are mostly pastoralists, and the country is home to several livestock species including the
Somali goat, Somali Sheep, and dromedary camels. Commonly found along the four roads to be
rehabilitated are goats, sheep, and camels. The goats and camels are bred mainly in the central and
South of the country and cows become more visible in all project sites but more so Bardhere,
Dhusomareb and Jowhar. The country has lost many of its wild mammals such as elephants to
poaching. The main wild mammals found in Somalia include giraffe, zebra, and hyena. One of the
most famous endemic mammals in the country is the long naked garanuug (Litocranius walleri). Other
endemic mammal includes the silver dik-dik (Madoqua piacentinii), one of the world's smallest
antelopes, and the Somali golden mole (Calcochloris tytonis). The country has several reptile species
of which one of the most renowned is the Bitis arietans Somalica commonly referred to as puff ader
snake. Many Gecko species are also found in Somalia including the endemic Hemidactylus taylori.
The country is estimated to have several hundred bird species including the ostrich and several dove
species.

4.4 Socio-Economic Environment and Population

4.4.1 Economy and Poverty

Agriculture is the most important sector, which accounts for 65% of GDP and employs 65% of the
workforce. The economy is based mainly on livestock and remittances/money transfers from abroad,
and telecommunications. Livestock contributes about 40% to GDP and more than 50% of export
earnings. Similarly, Somalia is the world’s fourth-most remittance dependent country, which makes up
about 20-50% of local economy5. Telecommunications on the other hand had been developed in the
country primarily by private entrepreneurs with their foreign investors from China, Korea, and Europe.
These facilities not only transmit electronic messages and data, these also are used to do money
transfers. The telephone density in the country is much denser than its neighboring countries.

In 2015, less than a third of the donor commitments were actualized due to lower oil prices and
bureaucratic hurdles. Domestic revenue is still insufficient to allow the government to deliver services
to citizens. The administrative and security sectors account for more than 85% of total spending while
economic and social services sectors account for about 10% of total expenditure. Poor collection
capacity, narrow tax base, absence of the necessary legal and regulatory frameworks, and lack of
territorial control hinder full revenue mobilization (World Bank 2016).

Poverty levels in the country is very alarming. UNDP in its 2014 report mentioned that the country has
a poverty rate of 73%, a life expectancy of 55 years, adult literacy of 31.8%, about 70% of the
population is below the age of 30, and a youth unemployment rate of 67%. In its 2012 report, UNDP
Somalia mentioned that the country had one of the lowest Human Development Index (HDI) in the
world with a value of 0.285. Inequality is high driven by the difference in poverty incidence in urban
settings (close to 60% in Mogadishu) and rural settings (52.3%) with IDP settlements (71.0%).

The food security situation has been worsened by the civil war and statelessness, and recurrent
droughts, as farmers have lost access to agricultural inputs and services formerly provided by the
state. The private sector has responded to a degree, but the lack of regulation might have led to

5
Remittances alone was estimated at USD $1.3 billion for the country, not only provide a buffer to the economy but also
are a lifeline to large segments of the population cushioning household economies and creating a buffer against shocks
23
misuse, and poor-quality control. While industry can provide an increasingly important contribution to
economic growth, it will be, for the foreseeable future, second to pastoralism and agriculture.

The Project can have a positive effect in alleviating poverty in both rural and urban centers. While
temporary disruptions of local residents live in terms of construction related impacts, these are only
temporary can be mitigated using standard engineering practices

4.4.2 Governance and Security

Somalia has recovered from a long period of conflict and lawlessness and the country is now in the
process of building public institutions. Somalia has adopted federalism and currently comprises of five
active Member States which are also building their government institutions. The country’s security
situation is poor with insurgents having control of many areas in the South of the country. These
insurgents continue to spread insecurity, especially in Mogadishu, through suicide bombers. The
country is developing its military capacity and aims to take over the provision of security in some parts
of the country from ATMIS.

4.4.3 Gender

Somalia has one of the highest gender inequalities in the world at 0.776 which ranks 4th in the world6.
The country has an extremely high maternal mortality (723 deaths per 100, 000 live births while the
adolescent birth rate for teenagers aged between 15 and 19 is 100.1 per 1,000 births. Rape, female
genital mutilation and child marriage rates, and violence against women and girls is common. Women
make up 56.6% of the workforce in agriculture/pastoralism which constitutes 60% of the local
economy. The number of women working in government had significant numbers at 1,912 (19%).
Much is to be desired in the education sector, where only 36.1% of pupils in the upper primary
education are composed of girls. Gender disparity is higher in upper grades due to economic
constraints and early marriage.

Culturally the role of women has been limited to domestic affairs, however because of legislative
changes their participation in the country’s governance and politics continues to grow. Currently there
is a 30% quoata declared for women representatives in both the lower and upper houses of the
parliament. According to recent data from the UNDP711 the 2017 share of women seats in parliament
was 24.3%. Traditionally the Somali women have been the “engineers” building the traditional homes,
aqal somali, and “food processors” making preserved meat referred to as oodkaq/muqmad. They are
also the fetchers of water for domestic use while it is the men who work at the well to provide water
for the herds. Somali women are actively involved in business mainly trading in household goods,
gold, and khat.

The Project should make a positive impact for women in terms of providing safe and convenient access
facilities to basic social services (education, health, government offices, etc.), and reducing travel time
for firewood which women can use the saved time for productive purposes (i.e. second livelihood,
school tutorial services for their children, etc.).

4.4.4 Access to Education and Health Facilities

6
United Nations Development Programme (2012). Somalia Human Development Report 2012:
Empowering Youth for Peace and Development, p. xviii.
7
http://hdr.undp.org/en/composite/GII
24
Prior to the civil war Somalis enjoyed free public education, however, since the collapse of the state
only 30% of the children are in school and fewer than 50 % of girls attend primary school8. Madrasas
play a key role in providing education for young children. These Islamic schools which are abundant
and easily accessible in nearly all parts of the country offer young children the opportunity to be literate.
Somalia’s healthcare provision is dominated by the private sector save for mother and child health
centers funded by donors. Along the roads nearly all the small settlements lack health care facilities
and people are forced to travel to nearby urban areas to seek medical treatment.

4.4.5 Land Use and Settlement Patterns

Land ownership is normally on a clan basis or degaan. Between 1969, after the coup of the civilian
government, the military government took control of most of the collectively owned community lands.
In the current constitution land is owned by the government, but again the central government does
not have the ability to enforce this ownership and land remains community property owned by the
different clans living in a particular area. Between these urban centers are scattered villages and small
town that serve as trade centers for the pastoralist communities. On the riverine parts of the project
sites. Beledweyne and Dolow areas, the communities can be described as agro-pastoralists.

4.4.6 Economic Activities

Somalia’s economy is built on pastoralism in which nearly 50% of the community participates (World
Banks, 2006). Historical data from the 1980’s shows agriculture generating 66% of the GDP and
Livestock and livestock products accounting for 51% of the GDP (World Bank, 2006). The
manufacturing sector generating less than 5% of the economy. Current figures from the World Bank9
shows the country’s 2017 GDP as 7.369 billion USD. The country’s economy is projected to grow at
a rate of 3%-4%10.

The telecommunication sector currently plays a major role in the country’s economy. Despite its long
coastline the fishing industry generates less than 5% of the economy (World bank, 2006). Of the five
confirmed project sites, Jowhar has a budding agriculture driven business. Barawe and Eyl are
dominated by aqua businesses while Bardhere and Jowhar is, another agriculture town but also does
a lot of cross border business with Kenya and Ethiopia like the rest of the districts for the Geod region.
Between Jowhar, Dhusomareb and Bardhere is where most of the county’s livestock are based. The
Southern side of the country, has direct links to Kenya and Ethiopia also presenting opportunities in
economic growth resulting from cross border trade between Ethiopia and Somalia. Now cross boarder
trading between Ethiopia, Kenya and Somalia shows import of agricultural product and fuel from
Ethiopia to the Beledweyne all the way to Jowhar, Barawe and Bardhere.

4.4.7 Waste Management

Waste management remains a big challenge in Somalia. There are no functional solid and liquid
waste management systems in nearly all of the country. Along the road waste dumping near the road
on the outskirts of settlements is a common practice. This is also the case in riverine areas such as
Dolow where waste is also dumped on the riverbanks. The SRCIP pilot could incorporate waste
management plan to divert away from the project apparently used as a dump site. This may need a

8
https://www.unicef.org/somalia/education.html
9
https://data.worldbank.org/indicator/NY.GDP.MKTP.CD
10
https://www.worldbank.org/en/news/press-release/2018/09/13/somalia-economic-update-
rapid-growth- in-mobile-money
25
 separate ESIA as it’s a standalone project.

4.4.8 Youth as a Vulnerable Group

According to UNFPA, 38% of Somalia’s population is at the age between 15-35 years. Most young
people live in the urban areas, 46% of all 15-29-year-old persons live in a city, followed by 25% that
live as nomads. Only 49% of male youth is literate, compared to 41% of female youth. 69% of current
youth are not enrolled in school. 3 in 10 youth are unemployed. 11 Irregular migration of youth
populations in search of resources of livelihoods, particularly from rural to urban areas may compound
existing challenges linked to youth vulnerability and unemployment.

A joint study by the World Bank and the United Nations on youth and attitudes to peace showed that
for youth peace is not just about ending violence but includes strong and accountable institutions
providing services and opportunities for all. For many respondents there was also a clear link between
violence, including domestic violence, at the local level and national level conflict. Peacebuilding
efforts, therefore, must start at home and at the community level.12

4.4.9 Clan Dynamics and Minority Groups

The traditional clan system, while evolving, remains a central and defining factor shaping political and
socioeconomic realities in Somalia. Clan affiliation is both a force that has influenced conflict and
violence as well as a mechanism for protection and dispute resolution. Customary traditions and
conventions help define rights and obligations among kin, clans, and subclans, with an emphasis on
the preservation of social stability over individual rights in communities and families. At the local level,
clan arbitration through the customary system known as xeer has helped regulate access to shared
resources, such as grazing areas and water.

Settlement patterns in cities are shaped by clan dynamics through ownership and development of
urban land, resulting in communities that are often segregated on the basis of clan. Clan affiliation
further affects the extent to which IDPs are included or excluded from development opportunities and
access to basic services. Consequently, a resultant pattern of inequality is emerging in Somalia’s cities
(Aubrey and Cardoso 2019).

Because of weak enforcement of the law, large disparities have appeared between customary tenure
systems and statutory law, engendering illicit appropriation on the part of those most powerful and
exacerbating the clan divisions. Because of the prolonged absence of a clear central government
authority and the subsequent erosion of legal systems, land and property have been subject to illegal
occupation and land grabbing; this remains the main source of violent conflict.
At the national level, the 4.5 power-sharing formula accords parliamentary power and other positions
to the four major clans, with minority clans comprising the remaining 0.5.

11 UNFPA, The Somali Youth in Figures, August 2016, accessed at: https://somalia.unfpa.org/sites/default/files/pub-
pdf/INFOGRAPHIC_YOUTH%20DAY%20%282%29.pdf
12
The World Bank, UN Somalia, UN Habitat, Youth as Agents of Peace in Somalia, 2018, p. 10.
26
 5.0 STAKEHOLDER CONSULTATIONS

5.1 Stakeholder consultations were carried out as part of the ESIA. The main goal of the
consultation process was to engage with key stakeholders that have an interest in or may be affected
by the project, to provide information, establish relationships and provide an opportunity for them to
provide feedback during the planning and preparation stage of the project. The objectives of the
process were to:
• Inform interested and affected stakeholders about the proposed project and
planned activities, including its foreseen positive and negative impacts.
• Gauge community attitudes towards the project, identify potential project impacts on
the community, and gather specific suggestions and concerns.
• Engage government entities whose area of responsibility is relevant to the project
and gather specific comments, suggestions and concerns related to ES aspects.
• Establish communication channels between the interested and affected stakeholders
and the project proponents and define mechanisms to maintain stakeholder
engagement in subsequent phases of the project, as well as a grievance mechanism.

5.2 The scope of the stakeholder consultation process was defined based upon the project’s area
of influence and its expected impacts. A total of approximately 27 individual interviews were conducted
(some of which engaged more than one person) durint the month of August 2022

▪ Government – This included federal, FMS, and municipal authorities whose area of
responsibility is relevant to the project, including the Federal Directorate of the
Environment and Climate Change (DoECC); the FMS Ministries for Energy and Water
Resources, Public Works, Housing and Reconstruction, Labor and Social Affairs,
Gender and Human Rights, Transport and Civil Aviation, Environment and Tourism,
Commerce and Industry; and the district administration of the five project sites.
• Community representatives from Bardhere, Barawe, Jowhar, Dhusmareb and
Eyl– This engaged community leaders and representatives including from women’s
groups, a youth association, an IDP camp, the business community/chamber of
commerce, and elders/clan leaders.
• International organizations – This included UN agencies whose mandate is relevant
to specific aspects of the project.

5.3 Overview of issues raised

This section summarizes the perspectives of stakeholders gathered during the consultation process.
A full report on the consultation process and issues raised is contained in Annex 1.

5.4 Consultations with government representatives

Overall, government representatives expressed support for the project and an interest in being
engaged in its development. The FSM line Ministries consulted saw the project as fitting with their
long-term objectives and policies relating to the environment, economic growth, and infrastructure
and services for citizens in the selected project sites. Some of the positive impacts they identified
27
included:
• Increasing electricity generation capacity which will eventually be leveraged to expand
energy access.
• Reducing GHG emissions and contributing to the government’s environmental and
climate change targets.
• Stimulating economic growth and development in the country and project sites,
including through job creation and by attracting private investment into the
country.
• Creating job opportunities especially for young men and women, which may help to
reduce crime and high unemployment.
• Providing the government with a more reliable electricity supply, clean cooking for
operations at a lower cost and addressing the problem of current frequent power outages,
which will enable it to be more effective in carrying out its mandate and delivering services
to the people.
• Generating revenue.
• Improving country infrastructure, especially with the hand-over of the infrastructure to
the state and local governments
• Serving as a model for other districts in Somalia.

Government representatives also raised specific suggestions and issues the project proponents
should consider, and in some instances, requested further information. The issues raised and the
response or follow up to those issues are outlined below:
• Information and updates were received about policies and regulations that are under
development, as well as laws that have recently been passed, that are pertinent to the
project.
• Questions were raised and suggestions were made relating to how the project manages
waste generated during construction and operation of the project, particularly e-waste, as
well as Workplace Health and Safety issues.
• Specific requests were made for further information about the project site, as well as to
share the ESIA and ESMP once it is completed.

5.5 Consultations with community representatives

Community representatives welcome the project. Generally, they viewed the development of energy
infrastructure as a positive development for the country. They also did not see the planned works as
posing risks to community safety or to other aspects of community life in project sites particularly
because the infrastructure will be in public areas, where access is restricted. Community members
highlighted the following positive impacts of the project:
• Creating of employment for those who will be hired as manual workers in the project during
construction and operation, especially for young people who are often involved in manual
work.
• Benefiting local businesses and suppliers that will provide various services to the project.
28
 • Reducing air pollution and GHG emissions and contributing to the protection of the
environment.
Some community members had expectations that are beyond the scope of what the project will
deliver. This included that the project would directly lead to increased access to reliable, cheap
electricity and clean cooking in the city and in the IDP settlements. They also made the following
suggestions to enhance the positive impact of the project on the community:
• Ensure early planning and preparation for the hand-over of the project to the local
government.
• Invest in additional energy projects that would satisfy the energy needs of the residents
of the country.
• Provide power for 24-hour street lighting, which would improve security in remote
areas, especially for women and from GBV.
• Create employment opportunities for particular groups, especially for women, youth
and IDPs.
• Hold further information sessions with community members in a safe area outside of
the green zone that community members can access.

5.6 Consultations with NGOs

NGO representatives highlighted that the project could provide a model for their energy and could
reduce its carbon emissions, as well as to increase the acceptance of solar a reliable source of energy
and clean cooking. They also highlighted that the project will result in cost savings for the people that
could allow for funds to be reallocated to programmes that benefit local people. They noted that this
project will both support the country efforts to fight climate change and achieve the Sustainable
Development Goals (SDGs) . NGOs also provided information about complementary initiatives in
project sites and Somalia, which the project could potentially link with in the future.

5.7 Response and follow-up to the consultation process

The issues raised during the consultation process have informed the ESIA and the development of the
ESMP for the project. The ESIA and ESMP will be publicly disclosed and available online. Physical
copies of the Executive Summary will be available in both English and Somali at a publicly accessible
location all project sites.

The project proponents will follow the Federal and SWS laws and regulations that are legally binding
of the country (detailed in Section 3). Because many relevant laws and regulations are under
development, the project proponents will coordinate closely with the relevant government ministries
and agencies on regulatory developments. Specific regulatory matters and information requests raised
by the government during the consultations will be followed up directly with the respective ministries
and government departments.
The project will increase electricity generation capacity from renewable sources in Somalia, however
it will not automatically increase access to affordable and reliable clean energy and clean cooking for
the city at large. Achieving this depends on other factors as well, including government regulation and
management of the energy sector, and additional investment in power generation and distribution
networks in the country.
29
The contractors for the project will be required to have a recruitment process that ensures equal
opportunities in employment. The Contractors will make information about open positions and the
recruitment process publicly available as widely as possible through locally appropriate
communication means, recognizing workers will need to pass a vetting process to enter the green
zone.
Advance planning for the hand-over of the project to the local governments will be carried out prior to
the hand-over through a hand-over strategy, which will include an environmental and social
management component.
The project will update the Stakeholder Engagement Plan (SEP) to communicate and disclose project-
related information to key stakeholders and will also establish a Grievance Redress Mechanism.

6.0 Environmental and Social Impacts and Mitigation Measures

6.1 Methodology

The ESIA identified potential positive and negative environmental and social impacts of the project, as
well as potential impacts of the environment on the project. Potential risks were first identified, and
then their significance was assessed. Finally, mitigation measures are proposed to minimize the
negative effects of significant risks and negative impacts.

The identification of potential risks and impacts, the assessment of their significance according to
predetermined criteria, and the proposed mitigation measures consider information collected from the
physical site and surrounding areas within project sites, the stakeholder consultation process,
secondary studies carried out by the project proponents or by others, and the professional judgement
of the team carrying out the ESIA.

The findings are organized in three sections:

• Potential Positive Impacts of the Project

• Potential Negative Impacts of the Project and Mitigation Measures
• Potential Environmental Risks to the Project and Mitigation Measures

The mitigation measures outlined below are not intended to be exhaustive in content but rather to
indicate in general to the scope of ESIAs and ESMPs. It is entirely possible that additional impacts will
be identified during impact assessment studies or during the implementation of the project, or audit
preparation and that they will require additional mitigation measures. In the ESIAs and ESMPs,
impacts shall be categorized according to project phase (planning, construction, operation, and
decommissioning) and for all project types.

The ESMP shall clearly lay out: (a) the measures to be taken during both construction and operation
phases of a subprojects to eliminate or offset adverse environmental impacts or reduce them to
acceptable levels; (b) the actions needed to implement these measures; and (c) a monitoring plan to
assess the effectiveness of the mitigation measures employed.

The environmental management program should be carried out as an integrated part of the project
planning and execution. It must not be seen merely as an activity limited to monitoring and regulating
activities against a pre-determined checklist of required actions. Rather it must interact dynamically
as a subproject implementation proceeds, dealing flexibly with environmental impacts, both expected
and unexpected. For all subprojects to be implemented under HAREACT project, the ESMP should

30
be a part of the Contract Document.
The major components of the ESMP include:
• Mitigation and enhancement measures
• Monitoring plan
• Estimation of cost of ESMP
• Institutional arrangement for implementation of ESMP

6.2 Assessment of potential negative impacts

The evaluation and assessment of impacts considers the interaction between the foreseen activities
and requirements during construction and operations and the social and environmental
receptors/resources. Taking into consideration the project location, the characteristics of the
surrounding environment, the foreseen construction and operation process, and the IFC
Performance Standards, potential negative impacts of the project in following areas were identified
as relevant for the ESIA:
• Air Quality
• Waste
• Noise
• Soil Quality
• Water Resources, Water Quality and Wastewater
• Biological Environment
• Municipal Services
• Community Health and Safety
• Workplace Health and Safety
• Glare and Glint
• Cultural Heritage

Once project-specific risks were identified, potential impacts were assessed to determine their
significance in relation to the following criteria: magnitude (the intensity or severity of the impact), areal
extent (confined to the project site, affecting immediate surrounding area, widespread), duration of the
impact (temporary, reversable, permanent). Where risks are considered significant (moderate or
major), the likelihood of occurrence given the controls in place was also considered as part of the
assessment.

6.3 Impact significance and likelihood criteria

Significance Definition
Negligible Little or no change in natural environment or socio-economic
conditions above baseline conditions.
Minor Localized and temporary change, with negligible residual effects
after recovery
Moderate Localized change of high severity that is longer-lasting but
reversable; or widespread change (affecting the surrounding
area/communities) that is of lower severity.
Major Widespread change that is of high severity.
Likelihood Definition
31
 Negligible Almost impossible/unknown
Low Very unlikely/very rare with controls in place
Medium Infrequent with controls in place, but potentially more frequent with a
failure of controls or safeguards
High Routine or likely with controls in place

Where the assessment process identified significant risks, mitigation or enhancement measures are
proposed to minimize the potential negative environmental and social effects. Minor risks are
integrated within the management plans of the facility. Mitigation measures are either incorporated
as an integral part of the project design or through environmental management and monitoring
measures. As much as possible, prevention is favored over mitigation or compensation. The
implementation and monitoring of the mitigation measures are outlined in the ESMP in Section 8.

6.4 Potential Positive Impacts of the Project

6.4.1 Reduced CO2 and air emissions

The project contributes positively to reducing CO2 emissions and other noxious emissions
associated with fuel combustion and burning trees for cooking. It will replace electricity generation
from diesel powered gensets with energy generated from renewable sources.

6.4.2 Development of Somalia’s renewable energy infrastructure

The project directly contributes to the development of Somalia’s renewable energy generation
capacity. The project will become part of the country’s long-term energy infrastructure, with ownership
transferred to the government of Somalia. The project may also promote and stimulate the growth of
the solar industry in Somalia, through the transfer of knowledge and skills, as well as by providing a
business model that can be replicated in other major towns in Somalia.
While the project increases electrical generation capacity from renewable sources in Somalia
specifically the selected project sites, other factors need to be in place in order to improve energy
access in Somalia at large. The project will not distribute power directly to local customers outside
of the selected project sites (this project does not allow this), however it could potentially supply
power to a local utility company that services customers in other areas, with a possible expansion
of the project phase 2. This could potentially incentivize regulation and complementary investments
that would expand energy access for households, businesses, in other areas in the country.

6.4.3 Improved efficiency of off-takers operations

The project will provide off-takers with more reliable power, compared with the diesel-powered grid,
clean cooking enabling them to function more efficiently and effectively. In addition, off-takers will
benefit from cost savings. These resources can potentially be reallocated towards programmes and
services that will benefit the populations that they serve.

6.4.4 Creation of employment opportunities

The project will create local employment opportunities in designated project sites, both directly and
indirectly. As outlined above, the direct labor force employed during the construction of the project
infrastructure is estimated to create temporary jobs for many unskilled workers who will be recruited
locally from project sites. The contractors engaged in construction and operation of the project will
32
have a clear recruitment policy and will publicize information about open positions and the
recruitment process through locally appropriate communication means, recognizing workers will
need to pass a vetting process to enter the project areas. In addition, the use of secondary service
providers during construction, may lead to indirect employment and opportunities for local
businesses. The consultations indicated that the construction process may create opportunities for
youth, who are often engaged in the construction sector.

6.4.5 Increased government revenue generation

The project will contribute to government revenue in the form of tax revenue and land rental income.

6.5 Potential Negative Impacts of the Project and Mitigation Measures

6.5.1 Air quality - Construction phase

Construction activities will result in localized, air quality impacts in the form of dust/particulate matter
from earthworks, and gaseous emissions from construction equipment, transport vehicles, and
generators used to supply electricity during construction. These impacts will be localized and
temporary. Due to the distance between the project site and residential areas, dust and air emissions
are expected to have a negligible impact on the surrounding communities. However, they will affect
the workplace environment.

6.5.2 Air quality - Operation phase

There are no GHG emissions associated with the operation of the project, however the combustion
process to run the diesel generators will used to generate air emissions. The overall effect of the
project will be to reduce GHG emissions and other air emissions associated with fuel combustion,
including particulate matter (PM), nitrogen oxides (NOx), and Carbon Monoxide (CO), compared
with the current situation in which the entire city’s electricity supply is powered by diesel generators.

6.6 Mitigation Measures

6.6.1 Construction phase

The contractors’ scope of work will include measures to minimize the potential impact of dust and
air emissions on the health and safety of workers. These will include:

• Dust management and suppression techniques such as covering excavated materials,

sprinkling with water and maintaining vegetation to reduce potential for windblown matter.
• Areas to be cleared of vegetation or topsoil shall be cleared only when required.
• Teams to wear dust masks as part of the recommended PPE where applicable.
• Teams to implement a Journey Management Plan.
• Vehicle speeds should be limited to 30km/h on unpaved surfaces.
• Ensuring vehicles and machinery are maintained in good working condition to reduce
noxious emissions and exhaust.

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 6.6.2 Operation phase

The developers and the contractors responsible for the construction and day-to-day operation of the
project will carry out measures to monitor significant environmental and social risks including the
mitigation aspects such as the minimization of the air emissions. These include:
• Emissions monitoring through theoretically quantifying the emissions using the
generator’s efficiency and the quantity and type of fuel used.
• Maintaining gensets in good working condition to improve efficiency and minimize
emissions.
• Remote monitoring and optimization of the project to minimize running of back-up
generators and fuel use.
• Ensuring fuels are stored in covered/sealed containers and safely handled on site to
minimize spills or leakage and to avoid potential fugitive air emissions.
• Ensuring that beneficiaries know how to use the cooking stoves.

6.6.3 Waste

6.6.3.1 Construction and Operation phase

The construction process will generate waste that includes packaging and wood scrap waste,
unused construction materials and off-cuts, civil wastes such as sand, cement, and aggregates, as
well as waste from the workforce. Excavated materials generated will be re-used for site filling and
leveling. Wastes generated during construction and operation of the project will also include small
quantities of hazardous wastes such as oils used in the maintenance of equipment, and human
waste from the workforce Wastes generated during the operation and maintenance of the project
will include e-waste, such as damaged solar panels and obsolete batteries, stoves and electronics.
The productive lifetime of solar PV equipment is typically greater than 30 years. The solar PV panels
have a 20-year performance guarantee, after which they will continue to produce electricity, but the
level of output is no longer guaranteed by the manufacturer. The productive lifetime of the solar
panels and other electrical equipment will be maximized to reduce equipment disposal rates,
including through good maintenance practices.

There are commercial waste disposal operators throughout the project areas, however recycling
facilities do not currently exist. Somalia does not currently have facilities for the recycling of e-waste,
however facilities for this are being established in several countries in the region. There are also not
currently qualified commercial or government waste vendors for hazardous wastes.

6.6.3.2 Mitigation measures

• Prior to the commencement of construction, an Environmental and Waste Management

Plan will be developed that identifies the waste streams, identifies opportunities for waste
reduction, reuse and recycling, and defines waste management procedures for
construction and operation of the project
• Contractors will be contractually obligated to follow the Environmental and Waste
Management Plan/procedures which will include procedures for waste reduction,
segregation, handling, storage, transportation, and disposal. This will include
documenting and reporting on the type and quantity of waste which has been stored,
transported, treated, recovered or disposed.
• E-waste will be stored safely at the site until it has been collected in sufficient quantity to
warrant transporting it to an e-waste recycling facility in the region or returned to the
34
 supplier for recycling.
• Project maintenance and waste management procedures will be designed to minimize the
quantities of hazardous wastes generated, including by substituting hazardous inputs with
those that are less hazardous and through stringent waste segregation. Hazardous
wastes will be stored on site in accordance with EHS guidelines to reduce the risk to
workers and of environmental contamination.

6.6.4 Noise: Construction phase

The use of machinery during site preparation and construction activities is expected to result in a
temporary, localized increase in ambient noise. Due to the nature of the earth works and installation
activities, the distance of the project site from residential areas, the existence of the perimeter walls
and bushes, as well as the baseline ambient noise in the area, the impact of construction noise on
the public is considered minor. However, construction related noise can have a significant impact
on the workplace environment, which can be mitigated through effective implementation of workplace
health and safety measures.

6.6.5 Noise: Operational phase

Noise generated during the operation of the project will primarily result from the running of the
generators, the transformers and inverters, and vehicle traffic. Generators and other noise
generating equipment will be housed in an acoustic enclosure such that the impact on noise will be
negligible. Overall, the noise should be reduced because the diesel generators currently used by
off-takers will be substituted by electricity generated by solar power project.

6.6.6 Noise: Mitigation measures

i) Construction and Operation Phase

The contractors’ will be contractually obligated to follow the project’s health and safety
procedures which will include measures to mitigate the potential impact of noise in the
workplace. This will include:
▪ Providing workers at the site with full, adequate personal protective equipment (PPE)
and posting signage at the site entrance indicating the type of PPE required in different
areas.
▪ Carrying out construction activities that will generate levels of noise of more than 70
dBa from 7:00am – 6:00pm

6.6.7 Soil Quality

6.6.7.1 Construction phase

The geological characteristics at the site are favorable for the implementation of this project. The
land at the site is flat and suitable for construction. This will reduce the need for earthworks during
construction.

The project is not expected to make important changes to the hydrographic. Based on a preliminary
site assessment, both riverine and overland flood risks are expected to be low due to the hydrological
and physiographic characteristics of the sites selected. Only minor drainage channels are foreseen.

35
Water will flow under and around the PV panels or transmission lines for example so that infiltration
and precipitation will not be significantly different from what exists under current conditions.
Although, waterproofed concrete surfaces can influence the rain flow and drainage, these areas are
small enough that they will not impact water flow and drainage at the site. Once a local contractor has
been selected, an assessment of potential future flood risks to the site will be completed. This will
include identifying if detailed hydrological studies are required and if the drainage design should be
modified to improve flood resilience.

Potential impacts on soil during the construction phase could result from contamination due to leaks
or spills of fuel or oils used or generated during construction, as well as to improper treatment of
wastewater or other wastes. These risks are moderate in severity, and the likelihood is low with
controls in place. In addition, soil compaction and removal of vegetation during construction could
increase the risk of soil erosion.

6.6.7.2 Operational phase

During project operation, the main risks to soil and groundwater quality are associated with potential
contamination due to leaks or spills of diesel, or due to improper treatment and disposal of
hazardous wastes, wastewater, or other wastes. No chemicals are used to clean the solar panels.

6.6.7.3 Soil quality: Mitigation Measures

To reduce the risk of soil erosion and the loss of soil cover:

• Removal of vegetation will be kept to a minimum, especially around the site perimeter,
and options will be explored to re-seed or re-plant vegetation as a surface cover.
• Construction vehicles will be limited to designated areas to prevent unnecessary soil
compaction.
• Assessment of potential future flood risks to the site will be completed, including
identifying if detailed hydrological studies are required.
• To reduce the risk of contamination due to leaks or spills of diesel:

- Diesel storage tanks and delivery bay will be fully bunded (110% maximum volume
bund) to prevent hazardous material / hydrocarbon spillage and environmental.
• Develop and implement procedures for the safe and orderly storage of fuels and refueling
of generators, as well as development of a Material Safety Data Sheet (MSDS) that
provides details and comprehensive information on controlled products related to:
- Health effects of exposure to the products
- Hazards evaluation related to the product’s handling storage and usage
- Measures to protect the workers at risk of exposure
- Emergency procedures in place
The Environmental and Waste Management Plan and procedures will address the management of
hazardous wastes and wastewater to prevent contamination.

6.6.8 Water Resources, Water Quality and Wastewater

36
 6.6.8.1 Construction phase

The demand for water at site for the construction phase is expected to be between 20,000 and 60,000
liters for the entire construction period. This includes water for sanitary purposes, maintenance of
machinery, mixing of concrete and module cleaning.
Construction of a boreholes is not foreseen as part of the project. Water will be obtained off-site from
a municipal supply point . The impact of water demand from the construction process on the
respective municipals is minor. Nonetheless, water will be managed efficiently to minimize
consumption. Potable drinking water for workers will be supplied separately. Black water will be
removed from site by a local service provider.
Most workers during the construction process will be current residents of project sites and will stay
in their own residences in town. Therefore, the workforce will have a negligible impact on total water
demand.

The nearest surface water and groundwater source Juba and Shabelle rivers in Bardhere and
jowhar respectively and Eyl on the Indian ocean. The likelihood that an accidental leak or spill of
diesel at the site would lead to contamination of surface water or groundwater is low. Nonetheless,
measures will be implemented to prevent spillage and environmental contamination.

6.6.8.2 Operation phase:

The main use of water during operation will be routine cleaning of the solar panels. No chemicals
are used to clean the solar panels.

- MITIGATION MEASURES FOR WATER RESOURCES, WATER QUALITY AND

WASTEWATER:

▪ Contractors will be provided with guidelines on efficient water use, to ensure water
consumption during construction and operation is kept to a minimum. Resource
efficiency initiatives is integrated into the ESMS.
▪ Mitigation measures to reduce the risk of diesel spills and contamination will be
implemented
▪ Wastewater management will be addressed within the Environmental and Waste
Management Plan.

6.6.9 Biological Environment

The project site is located within an urban area. The immediate surrounding areas are developed
urban settlements and agricultural land that have already been altered due to human activity and
do not have unique biological diversity or sensitive habitats. The project sites have been designated
for development. While there is vegetation at the site, any naturally occurring species and vegetation
has been degraded and removed due to previous clearance and use of the land. The impact of
construction and operation on the biological environment is considered negligible.

6.6.10 Municipal Services

37
The construction and operation of the project will make very limited use of municipal services. The
only municipal services that may be used during construction and operation of the project are
municipal water resources.

6.6.11 Community Health and Safety

6.6.11.1 Construction and operation phase

The likelihood that construction activities carried out on site will negatively impact community safety is
low. During construction and operation of the project, a small number of technical and managerial
personnel will come from outside of the identified cities. These personnel will travel to the site by air,
be housed in safe areas. The remaining workers will be residents of respective project sites.
Therefore, the impact of the workforce on the surrounding community is negligible.

6.6.11.2 Site security and presence of security personnel

In all the cities confirmed are controlled, and the area patrolled by ATMIS and government security
personnel. The project is subject to ATMIS and government security procedures and falls under its
security umbrella. The ministry coordinating with ATMIS and other stakeholders will carry out risk
assessments about the location of the project activities. . Any required safety mitigation measures will
be coordinated and implemented prior to commencing activities at the Project site.
In addition, a professional security company will provide site-specific security services at the project
site as an additional ‘layer’ of security. The role of the security personnel employed by the project will
be to monitor and observe the site, control access to the site, and deter theft or damage of equipment.

6.6.11.3 Traffic and coordination of access to project sites

Increased heavy vehicle traffic due to activities during construction and operation can have an impact
on community safety. Most of the project components will be transported to the site by air, which will
reduce the impact on traffic as well as security risks associated with transport which is subject to
project’s security risk assessments and management plans.
During construction, it is expected that project-related vehicle traffic to and from the sites will be limited
and will not lead to abnormal traffic.

6.6.11.4 Operation phase

The operation of the project will not increase heavy vehicle traffic and the impact upon local traffic is
negligible.

6.6.12 Mitigation Measures related to community health and safety

• Reduced driving speeds and use of well-maintained vehicles.

• Detailed survey of the route to site and conduct a route hazard survey to ensure all
mitigations are in place for the teams embarking to site.
• A professional security contractor will provide site security and their ability to adhere to
human rights standards and professional codes of conduct, as well as capacity to react
adequately in project sites, will be a part of the selection criteria.
• The contractor will be required to ensure that security personnel are well-trained and
conduct themselves in accordance with human rights standards and best practices,

38
 including the appropriate use of force and prevention of sexual exploitation, abuse, and
harassment.
• A Security Management Plan and security procedures will be developed, including
protocols for coordination of site security with government forces and ATMIS.

6.6.13 Workplace Health and Safety

- CONSTRUCTION AND OPERATION PHASE

Construction activities can potentially pose risks to workers health and safety. For example, workplace
injuries could arise from accidents during transport or at the workplace, accidental slipping, hazards
related to exposure to dust and emissions, or handling of hazardous materials.
As most of the workforce will be local workers who are resident in project sites, no special provision
will be made for workers accommodation or for transport to and from the site. The small number of
personnel who will come from outside of project during construction and operation will travel by air,
be housed by their contractors.
Due to the limited public health system in project sites, workers may be exposed to increased health
risks, including diseases associated with water and food contamination, pandemic diseases and
HIV/AIDs.
- MITIGATION MEASURES RELATED TO WORKPLACE HEALTH AND SAFETY

• The contractors involved in construction and operation of the project will be contractually
obligated to develop and implement a Health and Safety Plan that is in line with the
General EHS Guidelines, Site Protocols, Workers Code of Conduct and the EHS
Guidelines for Electric Power Transmission and Distribution, and its implementation will
be regularly monitored.
• Health and Safety Guidelines for personnel who are not resident in project towns will also
be developed covering issues such as code of conduct, accommodation, transport,
medical and evacuation procedures, and safety and security protocols.
• Health and Safety Risk Assessments will be carried out prior to starting activities.
• Training and awareness-raising programmed, and ongoing HSE refreshers, will be
provided.
• Contractors’ HSE representatives will carry out ongoing monitoring of HSE practices.
• Contractors and workers will be sensitized on HIV/AIDS and prevention measures.

6.7 Cultural Heritage and Archaeological Features

There are no registered archaeological or cultural heritage features in the project area. The likelihood
of a chance to find them is low, but in the event, this occurs, measures must be taken to avoid any
damage.

6.7.1 Mitigation measure

The contractor will be made aware of chance to find procedures and will implement them in the case
of a chance araise. This involves halting construction activities, protecting the area, and notifying the
appropriate local authorities.

39
 6.8 Impact of the Environment on the Project

6.8.1 Risk of dust on the project facilities

Somalia experiences periods of high wind and dust storms. In addition, the project site is exposed to
dust from vehicle traffic especially along the main road. Abrasion and deposits of dust on PV cells and
stoves can reduce their performance and energy output. Periodic module cleaning and maintenance
will reduce the impact of deposited dust on performance.
MITIGATION MEASURES ASSOCIATED TO DUST
Dust control methods will be implemented including maintaining and re-seeding vegetation
as a surface cover.

6.8.2 Risk of heavy rain and flash floods on the project

Bardhere and Jowhar are located within an area that is impacted by flash floods during heavy rains.
However, the project sites itself is in an area that has not been previously impacted by flooding and
is considered low flood risk.

6.8.3 Mitigation measures associated to rain and flash floods

Only minor drainage channels are anticipated to be required for rainfall runoff from the site, and no
flood drainage prevention is foreseen. However, once a local contractor has been selected, an
assessment of potential future flood risks to the site will be completed. This will include identifying if
detailed hydrological studies are required and if the drainage design should be modified to improve
flood resilience.

6.8.4 Risk of heat and extreme weather on workplace health and safety to the project

Somalia’s climate is hot with average daily high temperatures close to or over 90°F over the course
of the year. Exposure to extreme temperatures can pose a health risk to workers and can cause
heat-related illness. In addition, dust storms or other extreme weather events can adversely affect
workers health and safety.

6.8.5 Mitigation measures associated to heat and extreme weather

Temperature related stress management procedures will be implemented including:

➢ Monitoring weather forecasts for outdoor work to provide advance warning of extreme
weather and scheduling work accordingly.
➢ Adjusting work and rest periods, depending on the temperature and workloads.
➢ Providing a shaded rest area and temporary shelters to protect against the elements
during work activities.
➢ Providing workers with easy access to drinking water and adequate hydration.

Table 9-1: Potential Environmental and Social Risks and Impacts Associated with HAREACT project
Pre-Construction Phase
40
Design, Selection & Pre- Construction Phase
Aspect Environmental Environmental and Mitigation Measures
and Social Social Impacts
Risks
1-A. Social Issues
Land Loss of accruing Forced displacement Compensation in land since all land the
Resettlement benefits of using of IDPs by the construction happening is government
land including government; many owned. in cash at full replacement
shelter and IDPs are temporarily value for Assets in line with the RAP,
other temporal occupying Compensation for any replacement
old structure government land value for ‘loss of use of land’ and for
within the main cities temporary losses in line with the project
and towns ARAP.
Social Social exclusion Marginalization of Selection of the site in line with the
certain groups, approved design and or target criteria,
access to electricity Stakeholder engagement to cater for
and clean cooking the needs of the larger stakeholders,
Timely disclosure of project
information.
Social Heightened Underlying social Stakeholder engagement to cater for
expectation tensions, due to lack the needs of the larger stakeholders
of information as well especially the marginalized / minority
as negative influence clans,
about the project Timely disclosure of project
information.
Social Security threats Security issues i.e. The MoEWR to work with the Ministry
including the attack from Al of Interior and state level line ministries
risk of looting, Shabab, looting, to ensure the security of the workers,
security vandalism, security Project teams shall seek security
breaching, and breaching and approval and clearances form the
unauthorized unauthorized access project coordinator.
access to the to the sites.
Project teams shall be periodically
sites.
subjected to security awareness
campaigns.
SMP for the project shall be prepared,
collaboration between PIU and other
government entities on security matter
shall be done, PIU will Implement the
requirements of a Security
Management Plan specifically the
requirement security escorts within
determined project insecure areas.
Social GBV risks GBV Incidences All unskilled workers will be from the
especially SEA project sites
and SH GBV/SEA and SH risk assessment and
perpetrated by mapping of GBV services.
project workers

41
Design, Selection & Pre- Construction Phase
Aspect Environmental Environmental and Mitigation Measures
and Social Social Impacts
Risks
The GBV (SEA and SH) management
plans which include Codes of Conduct
for project workers,
Sensitization campaigns and
awareness creation on GBV.

Social Social exclusion Discrimination The employment of project workers

and against vulnerable should be based on the principle of
discrimination and disadvantaged equal opportunity and fair treatment.
groups, including Inclusive consultations and focus
IDPs, unemployed groups particularly to ensure
youth, women, participation of women and other
minority clans and vulnerable groups.
ethnic minorities,
No discrimination with respect to any
such as SSHUTLCs
aspects of the employment
relationship.
Hold sensitization meetings on
resources planning and conflict
resolution mechanisms; and
The contracts with third parties should
include non-exclusion requirements as
part of the monitoring system.
Violence Child Safety Children may be Enforcement of all Cadres of CoCs etc
Against exposed to various
Children forms of violence from
(VAC) - workers.
attributable
Child Labour The need to earn an Minimum age of project workers for the
to labour
income may force project is set at 18 years and above.
influx
underage children to All contracts shall have contractual
seek employment at provisions to comply with the minimum
construction sites age requirements including penalties
for non-compliance in-line with the
relevant national laws.
Project and Subproject environmental
and social management plans should
clearly forbid the use of child labor.
Grievances • Grievances, • Grievances from Grievance Redress Mechanism (GRM)
Complaints, contractual should be prepared to address
Disruption of workers engaged grievances. Specially, the
Activities to do heavy lifting environmental and social assessment
and and offloading. report for sub-project should contain a
Vandalism This could result
from delay in
42
Design, Selection & Pre- Construction Phase
Aspect Environmental Environmental and Mitigation Measures
and Social Social Impacts
Risks
payment of chapter on Grievance Redress at the
wages, sub-project level.
uncomfortable
working
conditions, work
areas and work
design
1-B Environmental Issues
Air Air Pollution The release of fugitive Measures should be targeted at
dusts avoiding forceful lifting and dropping
The release of fugitive down, as this will reduce chances of
dusts, offloading and fugitive dust and fibrils from being
challenges of storage released. Additionally, storage or
at warehouses holding areas should be cleaned and
wetted, and ventilated to avoid
conditions that could escalate dust
release.
If any of the materials to be delivered
and stored are hazardous, safe storage
must be provided to prevent
environmental and health and safety
impacts. If fuel is to be stored, tanks
must be surrounded by secondary
containment.
1-C Occupational Health and Safety Impacts
Transportation • Road Safety • Traffic Schedule deliveries of material/
of Materials congestion, equipment during off-peak hours
obstruction to Depute flagman for traffic control
pedestrian Arrange for signal light at night.
movement
Noise • Noise level • Noise from Measures should aim at reducing noise
increases offloading at disturbance, by setting up temporary
shipping docks noise barriers during offloading and
and airports is storage.
envisaged.
Stacking of Risk of • Offloaded and Measures should include ensuring
materials overloading and stored packages holding areas are sizable to contain
congestion of may overload procured commodities.
holding spaces holding areas and Reduction of overloading or crowding
restrict movement by limiting stacking to a particular area
and access for or section in the holding areas.
other operations Likewise, procured commodities should
be stacked in such a way that allows for

43
 Design, Selection & Pre- Construction Phase
Aspect Environmental Environmental and Mitigation Measures
and Social Social Impacts
Risks
space so as to reduce overloading and
restriction to access.

7.0 Construction Phase Impacts

The overall impact assessment of the proposed subprojects (substations and power lines) reveals that
most of the adverse impacts could be minimized or eliminated by adopting standard mitigation
measures; there is also scope to enhance some of the beneficial impacts to be generated from the
proposed subprojects. Table 4-2 below identifies the potential environmental and social risks and
impacts describes the mitigation and enhancement measures that could be applied to the subprojects
under HAREACT project. The safeguards team for the contractor with supervision of the Ministry
safeguards team will be responsible for the managing of the E & S risks and impacts.

Table 9-2: Potential Environmental and Social Risks and Impacts Associated with HAREACT project
Construction Phase

Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
2-A Environmental Risks and Impacts
Construction Environment Generation of sewage Construction of sanitary latrine/
of labour shed Pollution from and solid waste; water/ septic tank system for handling
for workers waste generation environmental pollution sewage waste,
Hire the services of a licensed
waste handling company,
Provide adequate waste bins at
site
Document all waste streams
originating from the site,
Ensure that waste disposal
mechanisms comply with existing
waste management practice that
is acceptable.
Drainage congestion and Provision for adequate drainage
flooding of storm water from the project
sites,
Provision of adequate diversion
channel, if required
Provision for pumping of
congested water, if needed,

44
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
Ensure adequate monitoring of
drainage effects, especially if
construction works are carried out
during the wet season
Felling of trees, Loss of vegetation cover Replant vegetation when soils
clearing of have been exposed or disturbed.
vegetation Plant trees to replace felled trees
Air • Air Pollution • The impacts on air Measures should be targeted at
may arise only from reducing emissions by retrofitting
fugitive dusts and with emission controls for
carbon emissions from vehicles.
exhaust fumes of Vehicle inspection and servicing;
vehicles as materials including obtainment of “Road
are transported to site, Worthiness” Clearance
certificates should be mandatory.
Dust control measures, including
speed limits for construction and
materials hauling vehicles, and
spraying of unpaved roads (if
water is available).
Soil • Soil Pollution • Leakages from (oil, Measures should address vehicle
vehicle fuel, hydraulic inspection; testing and tight- fitting
fluids) may occur of loosened bolts, junctions and
when vehicles are connection points.in vehicles.
transporting materials Hard-standing materials should
form temporary be placed on the ground prior to
holding or storage loading in warehouses.
areas to ESP and Additionally, impermeable
respective beneficiary material could be lined on hard
institution as well as standing in case leakages occur,
from the associated Availability of oil receptacles at the
facilities. sites,
• In addition, stockpiling Servicing of all machinery should
of equipment and be done at designated sites, and
materials at temporary
holding areas before Hire the services of licensed
delivery to final waste handler to dispose of
destinations could put hazardous waste from the site.
pressure on soil (in Ensuring that equipment refuelling
storage areas that are is done on hard surface or with
not floored) and cause temporary containment
compaction of soil.
Noise • Noise level • Noise impacts are Move equipment’s and materials
increases envisaged during the at suitable hours o without causing
movement of traffic jams.
45
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
exceeding equipment and
permissible limits materials to the sites
• EHS Guidelines
and WHO call for
maximum of 70
dB out of doors in
industrial areas,
and 55 dB (day)
or 45 dB (night) in
residential or
institutional areas
Waste • Generation of • Unpacking of Measures should be embedded in
Generation solid waste equipment and sub-project level waste
streams materials may result in management plans (WMPs).
generation of solid Measures should focus on source
wastes from reduction, sorting, collection,
packaging materials reusing, recycling, transporting,
and casings. containment, treatment final
• Removal of old and disposal etc Measure should
disused components include plans which address
may result in waste collection at source.
generation of
stockpiles of solid
wastes.
Water • Water • Some water resources Leaking parts should be fixed and
Resources Pollution within the program tightened.
area of influence could Put in place proper and adequate
be impacted if sanitation facilities for workers,
leakages occur from Servicing of all machinery should
vehicles transporting be done at designated sites, and
materials to the site.
Ensuring that equipment refueling
is done on hard surface or with
temporary containment
Vehicle inspection and servicing;
including obtainment of “Road
Worthiness” Clearance
certificates should be mandatory.
2-A Social Risks and Impacts
Grievances • Grievances, • Grievances from Implement GRM at the level of the
Complaints, PAPs within the sub-project
Disruption of program area of Early and continuous Stakeholder
Activities and influence. This could Engagement in mandatory
Vandalism be among other things
associated with traffic

46
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
delay during
transportation of
commodities,
temporary or
prolonged power
outages during meter
supply; or poor labour
and working
conditions
Land • Loss of • Forced displacement Compensation in cash at full
Resettlement accruing of IDPs by the replacement value for Assets in
benefits of government line with the ARAP,
using land Compensation for the
replacement value for ‘loss of use
of land’ and for temporary losses
in line with the project ARAP, and
Setting additional measures
relating to livelihood improvement
or restoration in line with ARAP.
Land • Risks related • Delay in Engagement with the parties
acquisition, to the compensation for land involved in the conflict,
compensatio uncertain land take
ns tenure and the
Resettlement clan power
structure.
Conflicts of • Risk of violent • Conflicts of interests Implement GRM at the level of the
Interest or non-violent may arise during sub-project. Frequent
conflicts decision making at the communication and transparency
program in leadership and execution of
implementation level, institutional responsibilities
between Contractual Mitigation measures should be
workers and general implemented through provisions
labour, etc. in the C-ESMP.
• Conflicts of interests Stakeholder Engagement in line
may arise between with SEP, Sensitization, and
contractual workers capacity building for all cadre of
and between workers should be conducted.
contractual workers Importantly, the HAREACT
and on-site security project should ensure that
personnel. Contractors sign a Contractor’s
• Code of Conduct (CoC);
Managers CoC and Individual
CoC.

47
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
Illicit • Risk of Illicit • Increased risk of illicit Measures should focus on labour
Behaviour Behaviour and behaviour and crime management, awareness and
Crime (such as theft and training and enforcement of the
substance abuse) Code of Conduct cadres. Labour
attributable to labour Management Procedure
influx. Additionally, provisions etc
there may be increase
in unprotected sexual
intercourse due to
labour influx.
Labour • Risk of social • Conflicts of interests Hire all unskilled workers from
Influx conflicts may arise among and selected project sites
• Labour between workforces Prepare and implement a Labor
disputes and • Theft, physical Management Procedure with
grievances assaults, substance requisite policies, Code of
Conduct, procedures, and
abuse and
appropriate processes undertake;
prostitution.
awareness creation of Labor
• Likely increase in Management Procecure and
migrant conduct training as necessary and
workers/followers enforcement of the CoC cadres.
etc
Gender- • Sexual • Women and girls may GBV risk assessment and
Based harassment, be exposed to sexual mapping of GBV services.
Violence SEA harassment, Implementation of GBV Action
(GBV) and exploitation, abuse plan.
Sexual and violence as a
Exploitation result of interactionsSensitization campaigns and
and Abuse
with workers and awareness creation on sexual
(SEA)
possibly followers. harassment, SEA, and other
• Also, females social issues attributed to labour
influx.
engaged in near-site
petty businesses may
suffer abuse from Application of AfDB Guidance
their Notes in work procedures and
benefactors/guardian interactions, especially those
s in instances where addressing social aspects.
they do not meet
projected sales for the Implementation of workers Sexual
day. Exploitation and Abuse / Sexual
• Sex workers may Harassment code of conduct for
all workers
contribute to the
spread or suffer
contracting infectious
48
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
diseases, STDs and
STIs due to labour
influx. There may also
be the likelihood for
women workers to
suffer sexual
harassment,
exploitation, and
abuse.
Violence Child Safety • Children may be Enforcement of all Cadres of
Against exposed to various CoCs etc
Children forms of violence from
(VAC) - workers.
attributable
to labour Child Labour • The need to earn an Minimum age of project workers
influx income may force for the project is set at 18 years
underage children to and above.
seek employment at All contracts shall have
construction sites contractual provisions to comply
with the minimum age
requirements including penalties
for non-compliance in-line with the
relevant national laws.
The contractors required to
maintain labour registry of all
workers with age verification.
Project and Subproject
environmental and social
management plans should clearly
forbid the use of child labour.
Labour Pressure on • Increased Demand The contractor shall develop a
Influx Infrastructure, on Social labour management plan for
Services and Infrastructure, project.
Utilities Services and Utilities The Contractor should prioritize
employing locals as casuals to
reduce the need for labour influx

49
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
Social Social exclusion • Discrimination The employment of project
and against vulnerable workers should be based on the
discrimination and disadvantaged principle of equal opportunity and
groups, including fair treatment.
IDPs, unemployed Inclusive consultations and focus
youth, women, groups particularly to ensure
minority clans and participation of women and other
ethnic minorities. vulnerable groups.
No discrimination with respect to
any aspects of the employment
relationship.
Hold sensitization meetings on
resources planning and conflict
resolution mechanisms; and
2-C Occupational Health and Safety Risks & Impacts
Community Exposure to • Considering that Applications of country and Bank
Health and household supply and laws and regulations suitable
Safety accidents transportation of measures and Community Health
construction materials and Safety Plan
to the specific site will
involve cross-country
movement, through
densely and non-
densely populated
areas etc, Community
Health and Safety
risks are very likely
Health and OHS Risks • Workers could suffer, Risk assessment and OHS
Safety at falls and traumatic Inspection: Before contractor
Work injuries worker performing her/his duties,
he/she will undertake a personal
risk assessment and a Health and
Safety Inspection of the
equipment to satisfy
himself/herself that it is safe to
proceed,
Testing structures for integrity
prior to undertaking work.
Implementation of a fall protection
program that includes training in
climbing techniques and use of fall
protection measures.
Establishment of criteria for use of
100 percent fall protection
(typically when working over 2
50
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
meters above the working
surface,
• Electrocution of Deactivating and properly
construction workers grounding live power distribution
lines before work is performed on,
or in proximity, to
the lines.
Ensuring that live-wire work is
conducted by trained workers with
strict adherence to specific safety
and insulation standards
Provision of appropriate PPEs
Provision for shutting down of line
in case of snapping of line
Regular monitoring of power lines
to prevent electricity pilferage
Training of workers against
electrocution,
Posting of safety signages to alert
workers on the danger,
Limit access to the possible
hazardous site,
Only allowing trained and certified
workers to install, maintain, or
repair electrical equipment.

Safety Safety of workers Erection of “no litter” sign,

provision of waste bins/cans,
where appropriate,
Raising awareness about hygiene
practices among workers,
A designated safety officer should
be present at work sites.
Availability and access to first-aid
equipment and medical supplies

Security risks Safety and Security of Ensuring security at workers

Personnel and Properties camp and project sites and
properties are under surveillance
in collaboration with law enforcing
agencies,
Use the requirements of the
prepared project Security
51
Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
Management framework. The
Security Management Plan (SMP)
for the project shall be prepared
as well, and collaboration
between the ministry and other
government entities on security
matter shall be done.
Comply with the Security
Management Plan for the project
to ensure the safety and security
of personnel and property.
Traffic • Traffic • Traffic impacts may Measures should aim at
increases occur when heavy establishing baseline traffic
and Travel duty vehicles are conditions in proposed sub-
delay conveying to and from project locations; ascertaining
• Vehicle and the respective sites. traffic density.
pedestrian This is likely to occur Schedule deliveries of material/
accident risk. along major inter- equipment during off-peak hours
state highways,
• Also risk of community/town/city
Depute flagman for traffic control
damage to routes needed to be Arrange for signal light at night
roads and plied during
property. supply/delivery:
Public Spread of • Infection of COVID19 • Awareness creation for all
Health COVID19 among the workers project workers on the signs
and symptoms of COVID-19,
how it spreads, how to protect
themselves and the need to be
tested if they have symptoms.
• Use existing grievance
procedures to encourage
reporting of co-workers if they
show outward symptoms,
• All workers shall be subjected
to rapid Covid-19 screening
which may include
temperature check and/or
other vital signs.
• Mandatory provision and use
of appropriate Personal
Protective Equipment (PPE),
• Installation of hand washing
stations (with soap..)

52
 Construction Phase
Aspect / Environmental Environmental and Mitigation Measures
Activities and Social Risks Social Impacts
Increase cases of • Spread of HIV/AIDS • Carry out periodic HIV/AIDS
STI and STDs • Increase STI/STDs in awareness programs for
the area workers and the beneficiary
community.
• Distribution of condoms to
workers and neighboring
communities’
• The project team should use
the services of local area
HIV/AIDs service providers to
undertake community
outreaches.

8.0 Description of Alternatives Scenarios Considered

This section examines and elaborate the alternatives to the proposed Households Access to
Renewable Energy and advancing cooking technologies project

Three different alternatives have been considered during the ESIA process: no development,
alternative siting and alternative power-generating solutions and technologies.

8.1 No development

This ESIA uses the alternative not to develop the proposed project as the scenario with which to
compare the environmental and social impacts of the electricity infrastructure construction and
operation.
If the proposed Households Access to Renewable Energy and advancing cooking
technologies project is not implemented, the project-induced environmental and social impacts
will not occur. In this case, choosing the no project alternative would most likely maintain the status
quo, however it could also result in changes from other actions.
If the project is not implemented, the people in the selected project sites will most likely continue to
depend upon diesel generators for their electricity needs and firewood for cooking. This will result in
higher GHG emissions and cause environmental degradation than in the scenario where this project
is not implemented. . In addition, the would-be beneficiaries would experience less reliable energy
supply and higher energy costs and unclean cooking techniques. This, in turn, inhibits their effective
and efficient operation and ability to deliver services to the public.

The potential alternative productive land uses are limited due to the site location and therefore the
opportunity cost is insignificant.
Furthermore, most of the potential adverse environmental and social impacts are minor and can be
avoided or successfully mitigated through adequate planning, monitoring and with the
implementation of mitigation strategies.

53
 8.2 Alternative site location

Key considerations in the selection of site location are whether the proposed solar facility will
interfere with existing land uses (e.g., agriculture), whether they could potentially impact biological
habitats or nearby designated/protected areas such as areas of critical environmental concern,
cultural heritage sites, or special recreation management areas, and whether they could impact
inhabitants or surrounding communities.
Other important factors influencing the selection of the proposed project site in Somalia are site
security and ability to reach people. For these reasons, the only area where the site could be located
in areas controlled by the FGS and FMS authorities, The MoEWR and the project proponents
considered several alternative sites within the country and selected the site, taking into consideration
current land use, planned and potential future land use, interconnection requirements, and suitability
of the land for solar installation.

This assessment concludes that the selected five sites are suitable to establish the electricity lines
and that there is no preferred alternative site for this project. Developing the existing sites will not
negatively impact surrounding communities or areas of biological or cultural significance nor will it
disrupt existing activities and land uses. The sites are suitable from a security and technical
perspective, and the technical and economic requirements are simplified due to their locations.

8.3 Alternative technology

Solar energy and clean cooking are a suitable renewable energy technology and much needed
cooking technique for Somalia due to the high level of solar radiation, the availability of land, as well
as the relatively low technological requirements for the projects implementation and operation and
the environmental cost of the current cooking technique.

The project has been designed based on system reliability, cost-effectiveness and to minimize
environmental impact. The entire system has been configured and sized to maximize the usage of
solar PV generated power, reducing the reliance on diesel generation, whilst also reducing on the
total cost of power and cutting trees for firewood.

8.4 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

This section describes the project’s Environmental and Social Management Plan (ESMP) which
describes how the project will deliver the E&S mitigation and management measures outlined in the
ESIA report. The ESMP describes the actions that should be taken during construction and
operation of the project to implement the mitigation measures, the institutional arrangements, and
responsibilities for implementing and overseeing the plan, and a monitoring framework to track
implementation of the mitigation activities and the ES performance of the project.
The purpose of the ESMP is to:
• Ensure continuing compliance with applicable Federal and F M S laws and regulations,
AfDB safeguard standards, EHS Guidelines and the project proponents’ corporate ES
policies.
• Outline the ways in which the potential impacts identified in this ESIA report will be
managed.
• Ensure that appropriate monitoring is undertaken, including the establishment of
a monitoring plan; and provide a framework for assessing compliance with
respect to ES performance.
54
This section presents the preliminary ESMP for the Households Access to Renewable Energy
and advancing cooking technologies project based upon the current stage of project
development and information available at the time of the ESIA. The ESMP will be refined, and specific
policies and management plans will be developed by the project proponents and their contractors as the
project planning advances, and after contractors are selected.

8.5 Institutional Arrangements

The MoEWR is responsible for the E&S performance of the project and for ensuring that Contractors
commissioned during the construction and operation undertake necessary measures to comply with
the ESMP. Contractors’ corporate Environmental and Social Management System (ESMS) will be
extended to the Project, and CBE’s E&S policies, guidelines and procedures will apply to the project
and will be followed by MoEWR Somalia. The EPC and O&M contractor(s) (“the Contractors”) will
be required to abide by these policies. This is to be included in the Contractors’ scope of work
(contract) and addressed in the Contractors’ management plan(s).

Project Implementation Unit will support MoEWR to oversee the delivery and monitoring of E&S
requirements, including overseeing and approving E&S policies, plans and procedures at the project
level and coordinating with and overseeing the Contractors. The social safeguards of the project will
be responsible for communicating standards and expectations for E&S performance to contractors,
monitoring the regulatory environment and ensuring operations are compliant with applicable
legislation, and ensuring inspections and audits are undertaken and corrective actions are taken
where necessary.

The ESMP will be implemented by the MoEWRs, FSM line ministries and contractors. The Contractors
will be required to develop specific management plans covering issues such as health & safety,
pollution prevention, and emergency preparedness that will be approved and overseen by the social
safeguards of the project. The Contractors will also provide Risk Assessments and Method Statements
which will describe the scopes of work, hazards present and relevant mitigation measures.

Contractors’ scope of work will include provision for training of workers and of local subcontractors
as necessary for them to implement HSE policies, procedures and processes, and Human Resource
policies, including sensitization on non-discrimination and harassment, and the Grievance Redress
Mechanism.

8.5.1 Monitoring and Reporting

The Project Implementation Unit (PIU) will develop regular reports (typically quarterly) which will
typically be required by the Bank. Monitoring of results and reporting will be a key responsibility of the
PIU. The PIU will be responsible for collecting, verifying, and collating information, integrating the M&E
reports, and submitting to the Bank both the quarterly and annual progress reports. The PIUs shall
collect and compile data to provide basis for a compressive mid-term review. The PSCs will also
undertake an end term review and final Implementation and Completion Results Report.
This ESIA has identified preliminary potential environmental and social issues and risks related to the
project activities and have proposed subsequent mitigation measures. To ensure effective
implementation of measures, the following monitoring and reporting system which include both internal
monitoring and reporting and external monitoring and evaluation. This will be enhanced further in the
management plans to be developed prior to conceptual design of project components.
The significance of monitoring stems from the fact that the inputs will go into the project design and
planning, including mitigation measures, are based largely on “predictions”. It is essential that the
basis for the choices, options and decisions made in formulating or designing the project and other

55
environmental and social safeguard measures are verified for adequacy and appropriateness.
Monitoring verifies the effectiveness of impact management, including the extent to which mitigation
measures are successfully implemented.
PIU shall assume the responsibility of leading the monitoring and reporting on the compliance of
project implementation. The PIU must put in place an effective internal monitoring mechanism. It shall
be fully capacitated to undertake such tasks thereby recruiting regional safeguards specialists for
effective monitoring of sub-projects.
The PIU (through the Environmental and Social responsible person) will assess the compliance of all
implementers’ activities against the environment and social impact assessment mitigation action
plans. Indicators would be identified in the framework and Plan documents and used as a baseline for
assessing progress on implementation. The reports will present all activities, including stakeholder
engagement activities, for the period and summarise the issues. The report and its annexes will also
detail the measures taken to address the issues, timeline of responses, as well as corrective and
mitigation measures to address grievances and analysis of trends.
The project monitoring framework shall develop standard reporting forms which shall provide for
quarterly and yearly reports. This will include:
• List of consultations held, including locations and dates, name of participants and designations.
• Main points arising from consultations including any agreements reached.
• A record of grievance applications and grievance redress.

• Construction supervision reports that include assessment of contractor’s compliance with

safeguards.
• Progress report on Capacity Building plan,
• Project Staff (or FMS Ministries of Energy) at the regional level will prepare consolidated
quarterly monitoring reports on respective sub-projects progress and challenges.

8.6 Summary of the ESMP for Construction and Operation Phases

This section summarizes the project’s ESMP for the construction and operation phase. This outlines
the mitigation measures that will be implemented to reduce significant E&S impacts, as outlined in
Section 6. Additional E&S Management Plans will also be developed and are described below.

56
Construction
Phase
Issue Mitigation summary Responsible party Timeframe

1) Air quality
• Air emissions from fuel • Ensuring vehicles and machinery are Contractor Throughout
combustion and machinery maintained in good working condition to construction
reduce noxious emissions and exhaust.
• Reduced driving speed of transport vehicles.
• Teams to implement a Journey Management
Plan.
• Dust emissions • Dust management and suppression Contractor Throughout
techniques such as covering excavated construction
materials, sprinkling with water, and
maintaining vegetation to reduce potential
for windblown matter.
• Teams to wear dust masks as part of the
recommended PPE where applicable.
• Areas to be cleared of vegetation or topsoil
shall be cleared only when required.
• Vehicle speeds should be limited to 30km/h
on unpaved surfaces.

2) Waste
• Environmental • Environmental and Waste Management Plan Project proponents & Project
contamination due to will be developed that identifies the waste Contractor(s) Planning
improper disposal, storage, Phase
streams, identifies opportunities for waste
treatment of hazardous and reduction, reuse, and recycling, and defines
non-hazardous wastes
Waste Management Procedures for
construction and operation of the plant.

57
 • Hazardous wastes generated to be Contractor (s)
minimized through waste planning and
procedures.

• Waste management procedures will be Contractor(s) Throughout

implemented covering waste reduction, construction
segregation, handling, storage,
transportation, and disposal. This will include
documenting and reporting on the type and
quantity of waste which has been stored,
transported, treated, recovered, or disposed.

• Facility for safe storage of waste, including Contractor(s) Throughout

hazardous waste and e-waste, to be construction
established on-site.
3-Noise
• Ambient noise from ▪ Providing workers at the site with full Contractor(s) Throughout
machinery and equipment adequate PPE and posting signage at the site construction
affecting health and safety entrance indicating the type of PPE required
of workers or others in the in different areas.
surrounding area. ▪ Carrying out construction activities that will
generate levels of noise of more than 70 dBa
from 7:00am – 6:00pm.
4-Soil Quality
• Soil erosion • Assessment of potential future flood risks to Project proponents & Project
the site. This will include identifying if detailed Contractor(s) planning
hydrological studies are required and if the phase
drainage design should be modified to improve
flood resilience.

58
 • Removal of vegetation will be kept to a Contractor(s) Throughout
minimum, especially around the site construction
perimeter, and options will be explored to
re-seed or re-plant vegetation as a surface
cover.
• Construction vehicles will be limited to
designated areas to prevent unnecessary soil
compaction.
• Soil contamination (or • Develop and implement procedures for the Project proponents & Project planning
contamination of surface or safe and orderly storage of fuels and refueling Contractor(s) phase and
ground water) due to leaks of generators, as well as development of a throughout
or spills of diesel Material Safety Data Sheet (MSDS) that project life
provides details and comprehensive
information on controlled products related to:
- Health effects of exposure to the
products
- Hazards evaluation related to the
product’s handling storage and usage
- Measures to protect the workers at
risk of exposure
- Emergency procedures in place
• Diesel storage tanks and delivery bay will be Contractor(s) Throughout
fully bunded (110% maximum volume bund) project life
to prevent hazardous material / hydrocarbon
spillage and environmental.

5- Water Quality, Water Resources and Wastewater

• Impact of water • Procedures for water use during construction Project proponents & Project
consumption on municipal to be developed and implemented for efficient Contractor(s) planning
water resources sustainability practices phase &
throughout
construction

59
• Contamination due to • Procedures for treatment and disposal of Project proponents & Project
improper treatment and sewage and other wastewater generated Contractor(s) planning
disposal of wastewater. during construction to be developed. phase &
• Wastewater to be collected from the site by a throughout
qualified service provider. construction

6- Community Health and

safety
• Un-authorized access to the • Perimeter fencing to be installed and access Project proponents & Project
site resulting in incidents or to the premises restricted to authorized Contractors planning &
accidents personnel and visitors only. throughout
• Misconduct by security • A Security Management Plan and security construction
personnel procedures will be developed, including and
protocols for coordination of site security with operations
the government forces and ATMIS, period
• All project activities should be done as per
the project’s SMP.
• Adequate modules on human rights issues
and gender topics are integrated into the
training program and well communicated to
security guards. Grievance Mechanism (and
other mechanisms) for reporting complaints or
abuses by security personnel to be available
to all workers and contractors and publicly
accessible through a visible site banner
displayed on site highlighting the various
channels of communication and the contact
people
• Risk of incidents affecting • Reduced driving speeds and use of well- Contractor(s) Project
public safety due to maintained vehicles. planning &
operation of heavy vehicles • Detailed survey of the route to site and throughout
on public roads conduct a route hazard survey to ensure all construction
mitigations are in place for the teams period
embarking to site.
7- Workplace Health and safety

60
• Occupational health and •
Develop and implement OHS Plan and Project proponents & Project
safety risks and hazards to procedures in line with the General EHS Contractor(s) planning &
workers Guidelines and the EHS Guidelines for throughout
Electric Power Transmission and Distribution construction
• Health and Safety Guidelines for personnel period
who are not resident in project sites will also
be developed covering issues such as
accommodation, transport, medical and
evacuation procedures, and safety and
security protocols.
8-Impact of the Environment on the project

• Impact of heat and extreme Temperature related stress management Contractor(s) Throughout
weather on workplace procedures will be implemented including: construction
health and safety • Monitoring weather forecasts for outdoor period
work to provide advance warning of extreme
weather and scheduling work accordingly.
• Adjusting work and rest periods, depending
on the temperature and workloads;
• Providing a shaded rest area and temporary
shelters to protect against the elements
during work activities.
• Providing workers with easy access to
drinking water and adequate hydration.

Operations Phase
Issue Mitigation summary Responsible party Timeframe
1-Air quality

• Fuel combustion • Emissions monitoring through Project proponents & Throughout project
emissions from diesel theoretically quantifying the emissions Contractors life
generators using the generator’s efficiency and the
• Fugitive emissions from quantity and type of fuel used.
fuel storage

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 • Maintaining gensets in good working
condition to improve efficiency and
minimize emissions.
• Remote monitoring and optimization of the
plant to minimize running of back-up
generators and fuel use.
• Ensuring fuels are stored in covered/sealed
containers and safely handled on site to
minimize spills or leakage and to avoid
potential fugitive air emissions.

2- Waste
• Environmental • Waste management procedures will be Ministry & Contractors Throughout project
contamination due to implemented covering waste reduction, life
improper disposal of e- segregation, handling, storage,
waste, hazardous transportation, and disposal.
waste, and non- • Documentation and reporting on the type
hazardous waste and quantity of waste which has been
stored, transported, treated, recovered, or
disposed.
• E-waste will be stored safely at the site until
it has been collected in sufficient quantity to
warrant transporting it to an e-waste
recycling facility in the region or returned to
the supplier for recycling.
• Hazardous waste to be stored safely at the
site until options become available for off-
site disposal or recycling according to best
practices.
3-Noise
• Workplace hazards due to • Providing workers at the site with Contractor(s) Throughout project
noise generating personal protective equipment (PPE) and life
equipment posting signage at the site entrance
indicating the type of PPE required in
different areas

62
4-Soil quality
Contamination of soil (or • Develop and implement procedures for Project proponents & Throughout project
groundwater or surface water) storage of fuels and refueling of Contractor(s) life
due to leaks or spills of diesel generators as part of Environmental and
Waste Management Plan
• Inclusion of spill scenario in Emergency
Response Plans.
5-Water Quality, Water Resources and Wastewater
• Impact of water • Procedures for efficient water use during Contractor(s) Throughout project
consumption on municipal operation, including module cleaning to life
water resources be developed and implemented.
• Contamination due to • Procedures for treatment and disposal of Contractor(s) Throughout project
improper treatment and sewage and other wastewater generated life
disposal of wastewater. during construction to be developed.
• Wastewater to be collected from the site
by a qualified service provider.
6-Community Health and Safety

• Un-authorized access to • Company will be selected to provide site Project proponents & Throughout project life
the project site resulting security based upon their ability to Contractors
in incidents or accidents adhere to human rights standards and
Misconduct by security professional code of conduct.
personnel • Adequate modules on human rights
issues and gender topics are integrated
into the training program and well
communicated to security guards
• A Security Management Plan and security
procedures will be developed and
implemented, including protocols for
coordination of site security with ATMIS,
and for authorization of access to the
green zone for contractors, workers and
service providers.
Grievance Mechanism (and other mechanisms)
for reporting complaints or abuses by security
63
 personnel to be available to all workers and
contractors and publicly accessible.
7-Workplace Health and Safety
• Occupational health and •
Develop and implement OHS Plan and Project proponents & Project planning &
safety risks and hazards to procedures in line with the General Contractor(s) throughout
workers EHS Guidelines and the EHS construction period
Guidelines for Electric Power
Transmission and Distribution
• Health and Safety Risk
Assessments will be carried out
prior to starting activities.
• Training and awareness-raising
programmes and ongoing HSE
refreshers, will be provided.
• Contractors’ HSE representatives will
carry out ongoing monitoring of HSE
practices.
• Contractors and workers will be
sensitized on HIV/AIDS and prevention
measures.
8-Impact of the Environment on the Project
• Impact of dust • Dust control methods will be Ministry and Contractor(s) Throughout project
implemented including maintaining life

and re-seeding vegetation as a surface

cover.
Impact of heat and extreme Temperature related stress
weather on workplace health and management procedures will be
safety implemented including:
• Monitoring weather forecasts for
outdoor work to provide advance
warning of extreme weather and
scheduling work accordingly.
• Adjusting work and rest periods,
depending on the temperature and
workloads.

64
• Providing a shaded rest area and
temporary shelters to protect against
the elements during work activities.
Providing workers with easy access to
drinking water and adequate hydration.

65
8.7 E&S Management Plans for specific aspects of the project.

The MoEWR Somalia will develop E&S management plans for specific aspects of the project.
Plans will include, but not be limited to:
• Environmental and waste management plan, including pollution prevention plan and
water management
• Occupational health and safety plan, including the risk assessments and methods
statement
• Emergency preparedness and response plan
• Transport plan
• Training plan
• E&S monitoring plan
• Chance finds procedure which outlines the process to be followed in the unlikely event
that previously unknown archeological or cultural heritage resources are encountered
during Project-related activities.

The Contractors will also be required, within their contract, to develop and implement E&S
Management Plans that are aligned with the General EHS Guidelines and the industry guidelines
for Electric Power Transmission and Distribution and CBE’s Code of Conduct and E&S policies.
These plans will need to be approved by the project proponent prior to commencement of work
and they will be monitored as part of managing the contractors’ overall performance.

8.7.1 Occupational Health and Safety Plan

The project will develop an Occupational Health and Safety (OHS) plan will set out the formal
working practices, processes, and procedures for OHS management for the project during
construction and operation. This should clearly define roles and responsibilities for the
Contractors and their personnel, and outline OHS processes for OHS risk management, training
of workers, management of sub-contractors, incident reporting and OHS audit.
It will also set out OHS procedures to establish safe work practices and prevent occupational
injury or accidents. This should include, but not be limited to, procedures for:
• Preventative maintenance such that tools, equipment and machinery used by workers are
properly maintained.
• Use of signage to inform workers and visitors of hazards, procedures and specific safety
equipment required.
• Provision and use of PPE including what must be used where.
• Procedures for the prevention and control of hazards related to fuel storage and re-fueling
of generators.
• Procedures for the cleaning of solar modules.
• Requirements for operating of motorized vehicles and equipment.
• Electrical safety including prevention and control measures for installing, maintaining and
repairing electrical equipment.
• Housekeeping and site management procedures including storage of equipment and
materials.
• Fire protection equipment to be maintained on site.
• Safe usage of advanced cooking stoves.
• Procedures for handling of both hazardous and non-hazardous materials and wastes to
66
 reduce the risks to workers (also to be addressed in the Environmental and Waste
Management Plan).

8.7.2 Environmental and Waste Management Plan

The project proponent will be responsible for ensuring that Contractors prevent and mitigate
pollution, use resources such as water efficiently, and effectively manage hazardous and non-
hazardous waste generated during construction and operation. An Environmental and Waste
Management Plan will be developed that meets the standards set out in the General EHS
Guidelines and CBE’s corporate policies and the Contractors will be required to abide by it. This
will address issues including but not limited to:
• Processes to prevent, or minimize, the quantities of wastes generated.
• Minimizing the generation of hazardous wastes, including by substituting hazardous inputs
with less hazardous materials and through strict segregation of waste to prevent
contamination.
• Procedures to safely store e-waste on-site, until this is collected in sufficient quantities to
warrant transporting it to a recycling facility in the region or returning them to the supplier for
recycling.
• Procedures to safely store hazardous wastes on-site, until commercial options become
available to dispose of them according to best practices. All hazardous waste (e.g., fuel, oil)
shall be stored in impervious containers in bunded areas of 110 percent capacity of the stored
material to prevent contamination in case of accidental release.
• Waste storage facilities will be in safe areas, enclosed, lined and covered to prevent
spreading into surrounding areas and contamination of soil or water, as well as spreading
due to rainwater. The area will be sealed off and operated with limited access and marked
with safety signs to indicate potential hazards and restricted access. All wastes will be stored
in color coded and clearly marked containers.
• Non-hazardous solid waste will be disposed of by a qualified local contractor.
• An inventory will be kept of all waste stored on site, and waste manifest forms completed
for all waste removed from the site.
• Efficient use of water resources including in the cleaning of solar panels.
• Supply of clean drinking water for workers.
• Procedures for the disposal of wastewater during construction and operation by a qualified
contractor.
• Procedures for pollution prevention related to diesel storage and re-fueling and equipment
maintenance.

8.7.3 Emergency Preparedness and Response Plan

Emergency situations are those implying collective danger to persons, material goods or the
environment. The project proponents will identify and assess major-accident hazards, and will
develop an emergency preparedness and response plan, to prevent major accidents and to limit
their adverse impacts on workers, affected communities and the environment. This will set out the
principles for safety and emergency management and define the roles and responsibilities of the
project proponents and Contractors, including the organizational structures, responsibilities,

67
procedures, communication, training, resources or other aspects required to prevent and respond
effectively to emergencies associated with project hazards.

8.7.4 Security Risk Management Plan

As outlined above, all the project sites are in areas controlled by the forces of the government of
Somalia, FMS state forces and ATMIS. All Contractors and personnel will require authorization
to from the local security officials, PIU to start working but doing a thorough Security Risk
Assessment and Security Management Plans.

The project proponents might need to contract a professional company to provide security at the
site premises. The company’s adherence to human rights standards, vetting of personnel to
ensure that they are not implicated in past abuses, standards of professional conduct towards
workers, visitors, and community members, and their training of personnel will be considered as
part of the selection criteria and due diligence process. The company providing site security
services will be located on the site premises and their primary role will be to control access to the
site, observe and monitor activity, and deter theft, trespassing and other infringements that could
pose a risk to the safety of workers, property, and visitors. Expectations of appropriate conduct
of security staff should be clearly communicated, and if permission to use force is granted, force
will only be permitted as a matter of last resort. Adequate modules on human rights issues and
gender topics will be integrated into the training program and well communicated to security
guards.

Informed by a security risk assessment, the project proponents will develop a Security Risk
Management Plan and protocols for the construction and operation of the plant in line with the
requirements of PS4 to ensure adequate security risk management, emergency responses
(including roles and responsibilities of private security and public forces) and duty of care for
project workers, project-affected parties and contractors. This will define the roles and
responsibilities of the project proponents and Contractors for site security and will outline
processes for coordinating with all security stakeholders. ATMIS and government security
personnel who have overall responsibility for security provision to all project sites. This will
include coordination of access to the green zone for Contractors and workers, and steps to
minimize security risks associated with the entry of project-related personnel.

MoEWR coordinate with government MDAs and ultimate oversight of the project security
guards of the project and will record all security incidents and investigate all allegations of
unlawful or abusive acts by its security personnel.

8.7.5 Decommissioning Plan

Decommissioning is defined as the close of operations, the removal of process equipment,

buildings and structures and carryout site cleanup and remediation if required. The expected
lifetime of the facility ranges between 25 to 30 years with appropriate preventative maintenance.
The facility lifetime may be extended further if obsolete equipment is replaced and upgraded over
time.
The FMS authorities manage and be responsible for the decommissioning, as MoEWR no longer
be involved in the Project. If decommissioning occurs before the transfer of ownership to FSM
authorities’ period, MoEWR will undertake this responsibility. The decommissioning process
should provide for:

68
 • Restoring the site to baseline conditions, which may include re-vegetation, depending
upon whether the land will be converted to other uses at the time of decommissioning.
• Disassembling the PV modules, mounting structures and electrical equipment, for
recycling at an approved facility or by the equipment manufacturer (for e-waste) or for
re-use.

8.7.6 Human Resources Policy

The project proponents’ Code of Conduct commits to adherence to the IFC Performance
Standards and IFC General EHS Guidelines in implementation of its’ projects, including IFC
Performance Standard 2 (PS2) addressing labor and working conditions. All Contractors are
required to comply with this Code of Conduct as a condition of their engagement with the project,
as well as to require compliance of all sub-contractors. In addition, all Contractors will be required
to comply with the applicable labor and employment laws in SWS, as reviewed in Section 3.
Finally, Contractors will be advised to be sensitive to workers’ religious practices, such as
allowing workers to

8.7.7 Working conditions and terms of employment

• A clear and understandable employment contract will be made available to all workers. This
contract will comply with the applicable labor and employment laws in SWS, as reviewed in
Section 3.
• In recognition of the vulnerability of migrant workers and trafficked persons who lack legal
status in a country, it is expected that Companies will conduct adequate diligence in selecting
any contractors that will be supplying labor and ensure that terms of employment for migrant
and non-migrant workers engaged in comparable work are substantially equivalent.
• Hourly and quota-based workers will not be required to work more than 48 standard hours of
work per week. All workers shall be guaranteed a weekly 24-hour rest period.
• All wages, including all legally mandated bonus pay and premium pay for overtime work, will
be paid in full, in legal tender, and in a timely fashion to workers, except when workers have
agreed otherwise.
• No Company shall employ persons, formally or informally, under the age of fifteen (15) for
general work and persons under the age of eighteen (18) for work involving any hazardous
activity.
• Workers will enter employment and contractor relationships at their liberty and will not be
forced into any kind of service that is not voluntarily performed.
• Proactive efforts will be made to protect workers from injury and illness. This entails the
identification of potential hazards and adequate responses through design, testing, and
work processes to eliminate all avoidable risks to employees’ health and well-being.
• For inherently hazardous workplace environments PPE will be provided at no cost to the
worker. In addition, workers will have the right to remove themselves from hazardous
situations without jeopardizing their continued employment.

8.7.8 Non-discrimination and harassment

• Contractors must be committed to establishing and maintaining a work environment in

which all individuals are treated with respect and dignity. Everyone has the right to work in
a professional atmosphere that promotes equal employment opportunities and prohibits
discriminatory practices, including harassment.
69
 • Contractors will accommodate workers’ religious practices and local customs, for instance
allowing workers to take breaks at prayer times.
• Contractors will be required to have a clear recruitment policy and will publicize information
about open positions and the recruitment process through locally appropriate communication
means, recognizing workers will need to pass a vetting process to enter the green zone.
• Employment decisions will not be based on personal characteristics unrelated to inherent job
qualifications. Companies will also take active measures to prevent and not endorse any
harassment within the workplace. The expectation is that reasonable accommodations will
be made for all disabled employees and that special measures of protection or assistance
will be targeted to underrepresented groups in the workforce.
• Contractors must make every reasonable effort to ensure that all concerned are familiar
with these policies and aware that any complaint in violation of such policies will be
investigated and resolved appropriately.
• Project activities will be conducted with sensitivity to risks that may be specific to women,
including sexual harassment.
• Sexual harassment constitutes discrimination and is expressly forbidden. Sexual harassment
is defined as unwelcome sexual advances, requests for sexual favors and other verbal or
physical conduct of a sexual nature.13
• Sexual harassment occurs when, for example: (1) submission to such conduct is made either
explicitly or implicitly a term or condition of an individual's employment; (2) submission to or
rejection of such conduct by an individual is used as the basis for employment decisions
affecting such individual; or (3) such conduct has the purpose or effect of unreasonably
interfering with an individual's work performance or creating an intimidating, hostile or
offensive working environment.

• The Contractor will explicitly prohibit retaliation by any employee against any other
employee who has brought forward an issue or compliant in good faith through Company
complaint procedures.
• Reporting of all perceived incidents of discrimination or harassment, regardless of the
offender's identity or position, must be encouraged. Individuals who believe that they have
been the victim of such conduct may discuss their concerns with their immediate supervisor,
the Contractor leadership, the project proponents’ leadership, or through the CBE
anonymous reporting hotline.
• The Contractor will be required to have a Complaints Procedure in place (both informal and
formal), which allows for such reporting.

8.7.9 Stakeholder Engagement Plan and Grievance Redress Mechanism

- STAKEHOLDERS ENGAGEMENT PLAN

The project will develop and implement a Stakeholder Engagement Plan to communicate and
disclose project-related information to key stakeholders in a proactive manner and will establish a

13
Sexual harassment may include a range of subtle and not so subtle behaviors and may involve individuals of the same
or different gender. Depending on the circumstances, these behaviors may include, but are not limited to: Unwanted
sexual advances or requests for sexual favors; Sexual jokes and innuendo; verbal abuse of a sexual nature; Commentary
about an individual's body, sexual prowess or sexual deficiencies; Unwelcome notes, emails, phone calls, messages, or
gifts of a sexually suggestive nature; Leering, whistling or touching; Insulting or obscene comments or pictures; Other
physical, verbal or visual conduct of a sexual nature.
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Grievance Redress Mechanism. The Stakeholder Engagement Plan will include:

• Description of the project proponents’ requirements for public consultation and disclosure of
project-related information.
• Description of the roles and responsibilities of the project proponents and contractors for
stakeholder engagement activities.
• Regular liaison with the relevant Federal, SWS, municipal and district authorities to keep
them informed of project-related activities.
• Timely and appropriate disclosure of information about planned activities to neighbors and
the local community prior to and during construction, or non-routine activities during
operation, if such activities may cause local disruption such as noise or abnormal traffic.

The project will designate in-country lawyers on standby during the construction period to be
responsible for coordination of the Stakeholder Engagement Plan and liaison between the project
proponents’, Contractors, the relevant SWS and district authorities, and other community
members.

8.7.10 Grievance Redress Mechanism

Grievance Redress Mechanism (GRM) is a set of simple and transparent procedures that provide
its users with access to safe and confidential means of expressing complaints/concerns and
guidance to staff on how to handle grievance to the point of giving feedback to the complaint.
The ministry will put in place GRM that is designed to ensure that community members, as well
as the workforce, have a safe, easily accessible, and confidential way to raise grievances and to
resolve their concerns. It allows the project to be active in identifying solutions to grievances and
to resolve issues efficiently and effectively, and to resolve issues by consensus.

The establishment of the GRM will be based on the following guiding principles; Commitment and
fairness, transparency, and accountability towards the Project Affected Persons (PAPs):

• Participation – Local stakeholders will be involved in the design and establishment of

the mechanism to ensure it is culturally-sensitive and appropriate to the local context.
• Confidentiality - To create an environment in which stakeholders feel safe to raise
their grievances, information about complaints is treated confidentially and only shared
with designated staff to resolve the issues and give feedback.
• Clear information – It will be safe and confidential to raise grievances without fear of
victimization, and the process for resolving complaints will be transparent.
• Safe access – Easily accessible, well-publicized focal point or user-facing ‘site banner’,
in a location deemed to be credible and accessible by community members, and multiple
channels of communication will be available, including phone, email, WhatsApp and SMS.
- The GRM process encompasses five steps:
• Publicize the mechanism
• Receive and register complaints
• Review and investigate complaints
• Develop resolution options, respond to grievances, and close out
• Monitoring and evaluation

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 - The GRM Procedure will include:

• Ensuring the GRM is clearly communicated to workers and to the public and that
mechanisms to provide feedback are established, including through a ‘suggestion box’
and through mobile communication.
• Documentation of the complaint in a Grievance Form through an interview with the
person raising the complaint (carried out sensitively by a designated Grievance
Officer)
• Review and investigation of the complaint, and direction the complaint to the
appropriate level of management, depending on the nature of the complaint,
• Feedback to the person filing the complaint and a meeting scheduled to resolve the
complaint (normally within 2 weeks of filing), and documentation of the resolution.
• If there is no resolution, the case can be referred for legal action as a last resort.

The GRM will include an approach to managing complaints related to SEA, GBV, or sexual
harassment in a manner that is survivor centered. This focuses on ensuring the response to the
incident is in line with the wishes of the survivor and ensures their safety, respect, confidentiality,
and non-discrimination. The approach will protect confidentiality of individuals and preservation
of evidence without compromising access to justice, while also enabling links to referral pathways
and local organizations for support services. It will also aim to strengthen the speed and
effectiveness of response, should such an incident occur, through well-functioning protocols and
remedial actions to enable safe and ethical care of survivors.

8.7.11 Mechanisms to receive complaints

The project will designate in-country lawyers to receive and handle complaints through the GRM.
These in-country contact persons will receive special training in handling cases related to GBV
and sexual harassment in a manner that is sensitive to survivors needs and wishes, including
ensuring they are equipped to connect survivors with non-legal support services.
Training module on the Grievance Redress Mechanism and how it functions will be also provided
to security guards.

In addition, the project has partnered with Ethics Point to establish an anonymous reporting hotline
to solicit information about suspected breaches of the project’s ethics, discrimination, health,
safety, environment, or governance policies. This hotline information will be made accessible to
all Contractor employees and sub-contractors and its use should be encouraged. Reports can be
made anonymously and securely and are shared with the legal and Human Resources leadership.

8.7.12 Monitoring Plan

The project proponents will be responsible for monitoring the risks identified in the ESMP and
performance and compliance with E&S policies and plans. Contractors’ compliance with E&S
and Human Resource policies will be incorporated as part of the contractors’ management plans
and will be given the same priority as other aspects of their performance. The following describes
monitoring arrangements for certain components of the ESMP:

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 - MONITORING AIR QUALITY

During operations, the air emissions from the plant will be theoretically modeled using the
quantities and type of fuel used, and the specifications of the generators, on an annual basis.

- WORKPLACE MONITORING

The project proponents EHS Manager will provide oversight over Contractors’ compliance with
the intent of the Human Resources policy and E&S policies and plans. This will include period
inspection and labor audits to document Contractors’ compliance.

Contractors will be required to have occupational health and safety monitoring programmes in
place, including safety inspection and testing of equipment of tools in place, and to keep a record
of this. Monitoring will include:

8.7.13 Compliance auditing

a) The Contractor’s HSE officer will conduct monthly site audits of all construction
related activities.
b) On completion of the construction activities, the contractor’s project supervisor
together with HSE Project Manager will conduct a site inspection. Any items
requiring attention shall be included in a post-construction audit report.

c) On completion of the defect’s liability period, EHS Project Manager and the
contractor with the view of determining whether outstanding matters from the
post-construction audit have been adequately addressed.

8.7.14 HSE Incidents

d) The Contractor’s HSE officer shall maintain a register of all HSE related incidents
occurring as a result of the activities associated with the contract. HSE related
incidents that shall be recorded include (but are not limited to):
Fire
- Accidents
- Fires
- Spills of hazardous materials that contaminate soil or water resources.

8.7.15 Non-compliance with the HSE

e) Each HSE related incident will be investigated by the project supervisor and an incident
report forwarded to the ministry’s PIU’ HSE Project Manager. An incident report will be
presented within three working days.
f) HSE incident reports will include as a minimum, a description of the incident, actions
taken to contain any damage to the environment, personnel or the public, and the
corrective actions to repair/remediate any damage; and
g) Prescribe additional measures that may be required to remediate damage resulting from
the incident and/or to prevent similar incidents occurring in the future.

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 8.7.16 Training

The contractor is responsible for ensuring that their workers are provided HSE training and
relevant site inductions and orientation. In addition to formal training, the contractor should
undertake toolbox talks. A training register will be kept on site for all training conducted as proof
for auditing purposes. The HSE training will include but not limited to the following:

- The importance of conforming with all HSE policies.

- The HSE impacts of the proposed activities.
- HSE benefits of improved personal performance.
- Worker roles and responsibilities in achieving conformance with the client’s HSE
policy, procedures and this ESMP including associated procedures and emergency
preparedness and response requirements.
- Potential consequences of departure from specified operating procedures
- Mitigation measures required to be implemented when carrying out their work
activities.

8.7.17 Equipment maintenance

- All construction plant and equipment, tanks and machinery shall be maintained in a good
state of repair throughout the construction period.
- Equipment maintenance will be carried out on an impermeable surface.
- Leakage from equipment will be prevented by regular inspection and repair.
- Should a leak or equipment malfunction be detected, appropriate personnel shall be notified
immediately, and every effort made to prevent further leakage.

8.8 Monitoring hazardous wastes and e-Waste Management

A register will be maintained for all hazardous wastes and e-waste. This will specify types and
quantities of wastes and means of storage and/or disposal. Waste manifests will record the non-
hazardous solid wastes removed from the site, as well as the disposal of wastewater, by qualified
local contractors. This will include recording the quantities of waste removed, the details of the
contractor who will transport the waste, the transit points and destination of the waste, and the
intended method of treatment, disposal, storage, re-use, recycling, or disposal off-site. Contractors
will provide monthly and annual waste reporting. The project proponents’ EHS Manager will review
these reports and the waste manifests and provide overall oversight over the waste management
contractors.

9.0 Conclusion and recommendations:

9.1 Conclusions
-
Almost the entire projects predicted no adverse and insignificant environmental and social impacts
both during construction and operational phases. This is because, the sites of project activities are
state owned reserves and located far from and will have adverse effect on human settlements. Where
the impacts are predicted, they are short term and reversible at reasonably very low costs. These
74
impacts are manageable; most of them can be minimized through engineering solutions easily
incorporated into project design. However, it is necessary to ensure that the ESMP and monitoring
plan are well implemented.
-
In the absence of the projects, the impacts to both the social and environment will substantially be
very high than with the projects as energy accessibility and infrastructure are highly linked to the
people’s livelihoods and environmental degradation. Without the project, the community will continue
to degrade the environments e.g. charcoal burning as alternative livelihoods and source of energy
Worst still, failure to implement the projects will likely raise serious concerns on the
legitimacy/governance of the Federal Government to effectively deliver public goods and services and
more importantly threatening livelihoods situation to already impoverished population in Somalia. With
HAREACT project, public image of Federal government will improve and help them gain legitimacy
and ultimately help the government find lasting peace and recovery process of the country.

Since the projects locations have yet to be assessed by the engineering design, continued monitoring
needs to be carried out to examine whether remedial actions are required to deal with unforeseen
impacts, if any. In addition, this the ESIA and ESMP need to be updated if the final engineering design
leads to major changes in the existing project plan. In this context and view of above findings, the
consultant recommends that the ESIA and ESMP need to be submitted to responsible line
Government Ministry of Federal Government of Somalia, region State Administration and the African
Development Bank for concurrence and issue of no-objection certificate.

9.2 Recommendations

Implementation: It is recommended that the proposed HAREACT project be implemented in

compliance with all the relevant legislation and planning requirements of Federal Government of
Somalia (FGS) and African Development Bank (AfDB) at all times. In line with this, the proponent and
the contractor must take the legislative framework provided in this report into consideration, during
and after the implementation of the project, as will be appropriate.
-
ADHERENCE TO ESMP: IN ADDRESSING THE ENVIRONMENTAL AND SOCIAL ISSUES, THE
CONTRACTOR
And the project implementing unit mPIUust follow the mitigation guidelines provided under ESMP.
This
will ensure the Environmental and safety of farmers and the neighboring communities. It is also
recommended that an Environmental and safety officer should be stationed in the proposed project
site, during the whole construction phase. The safety officer will make sure that all the workers follow
the safety rules.
ANNUAL ENVIRONMENTAL MONITORING AND AUDIT:

During Construction phase the PIU team and the Contractor is required to undertake Environmental
Monitoring to ensure that the Construction is done in compliance with the provisions of the ESIA, in
addition, MoEWR should undertake an environmental audit (EA) of the project, as required by the
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country laws. This will ensure that the project does not lose track of its good environmental
management record achieved during construction. This should be done by seeking the services of an
Environmental and Social safeguards Consultants who should be Lead Experts. The team should
consist of the following experts at minimum:

- Lead Environmental Consultant (Senior Environmentalist/Team leader)

- Socio-Economist Consultant
- Social safeguard Specialist
- GBV/Gender Specialist

10.0 References

1. Good Practice Note Addressing Gender Based Violence in Investment Project Financing
Involving Major Civil Works, 2018.
2. International Development Association, Project Appraisal Document on Proposed Grant in
The Amount of US$ 150 Million to the Federal Republic of Somalia for Somali Electricity
Sector Recovery Project, May 18, 2021.
3. Preventing Sexual Exploitation and Abuse. (n.d.). Retrieved June 24, 2021, from
https://www.un.org/preventing-sexual-exploitation-and-abuse
4. Provisional Constitution of the Federal Republic of Somalia, 2012
5. The Somali Penal Code of 1962,
6. The Somalia Agricultural Land Law 1975,
7. The Somalia Labour Code of 1972
8. The Somalia National Environmental Policy 2015,
9. The Somalia National Gender Policy 2016,
10. UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials firearms,
11. Verena Phipps and Adrian Cutler (2020) based on a preliminary report and research by Reidar
Kvam and Caroline Giffon-Wee SOCIAL RISKS IN SOMALIA, A Country-Level Assessment
and Proposed Management Approach, December 2020.

11.0 Annexes

11.1 Annex: Stakeholder Consultations Report

* This report has been redacted to protect the anonymity of stakeholders interviewed

11.2 Introduction

This report has been prepared by the environmental and safeguards team of the MoEWR to
present and compile the findings of the stakeholder consultation process undertaken in Somalia
in February 2022 in connection with the ESIA for the proposed Household Access to Renewable
Energy and Advanced Cooking Technologies (HAREACT) project. The E&S team carried out
face-to-face consultations with:

• Government and district administration officials

• Non-governmental organizations

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 • Community representatives

In addition, several remote interviews (via WhatsApp, Teams) were held with NGOs and other
representatives of the Federal Government of Somalia (FGS) as well as state level government
officials.

The stakeholder consultations served several objectives, including i) introducing the project and
its anticipated impacts to community members and other interested stakeholders, ii) allowing
stakeholders to present their views of the project, and raise any concerns or suggestions and iii)
establishing communication channels between the developer and key stakeholders in all the
project areas.

11.3 Methodology

The E&S a 3-step approach to undertake public consultation for the proposed project. During the
inception phase, the team, and the ministry had a kickoff meeting with the stakeholders who may
be affected by or interested in the project were identified, and questionnaires were developed for
carrying out stakeholder interviews. Thereafter, the team undertook a desk review of the context
for the project in project areas to understand primary aspects such as the governance structure,
legal framework, and the environmental and socio-economic context. The stakeholders included
i) Government (state and federal level) and district administration, ii) Elders and community
representatives, iv) women and youth group representatives, in addition, several interviews were
carried out remotely with representatives of the Federal and state government officials and local
and international agencies.

Figure 1: Stakeholder engagement process

Inception Data collection Reporting

• Site visit • Collation of collected
• Kick off
meeting
• Preparation of data • Key informant Information
collection tools interviews
• Desk review • Drafting the stakeholder
• Mapping of engagement report
stakeholders

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11.4 The data collection phase began with a site visit to understand the nature of the environment
at the site and in the surrounding area. EMC proceeded to undertake the key informant interviews
during which we i) introduced the project to interviewees, ii) obtained their views on how the project
would impact the community and the government, iii) got feedback on how the proposed project fit
with the interviewee's activities/goals and iv) obtained information from government stakeholders on
laws, policies, and regulations that developer would need to consider during project implementation.
Each interview lasted between 15-20 minutes, including obtaining consent. Discussions were
documented using pen and paper. A summary of the main points from each interview is presented in
this report.

11.5 Outcome of the stakeholder engagement

In general, the respondents welcomed the project and saw it as a positive step towards
developing Somalia’s energy sector and promoting clean cooking technologies. Federal and
state level governments viewed the project as aligned with their policy and development goals
related to climate change, and sustainable development, and development of Somalia’s energy
sector. In addition, respondents highlighted that the project would create local employment,
generate revenue for government, and provide a model for similar projects in Somalia.

Due to the prevalent lacks access to affordable, reliable electricity and clean cooking technologies
across the country there are high expectations that the proposed project will change this situation.
However, the proposed project, during phase one, intends primarily to supply power and cooking
technologies to small number of people in proportion to the need. In addition, the installed
capacity will not be sufficient to meet Somalia ‘current and future energy demand. Nevertheless,
the proposed project was viewed by interviewees as a step in the right direction to reduce tariffs
which are prohibitively high for many customers, improve reliability as well as promote clean
cooking.

Details of the stakeholder engagement are presented in Table 2 below. Several issues were
raised during consultations with government officials that the developer needs to follow up,
including:
1. Ensure that further information is provided to relevant State ministries about the project.
This should include details of the project site and design that may be relevant to the future
potential expansion of energy infrastructures in project locations and the sustainability of
the project.
2. Ensure that information is provided to relevant State ministries on the land lease
agreement, and that coordination takes place across government to follow all the
applicable safeguard country laws and Bank regulations
3. Monitor regulatory developments related to labor and employment, including following
up with the relevant State Ministries
4. Ensure that a copy of the ESIA report and ESMP are shared with relevant State and
Federal Ministries/services once the project is finalized.
5. Clarify with the local governments the requirements related to registration of the
contractor’s employees, agreements with the Federal and state level ministries and
licenses

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Table 11.1: Responses from consulted stakeholders

Name of
Organization Comments
respondent
Federal Federal Ministry of • The project aligns with the Ministry's policy
Government Energy and Water objectives.
official. Resources
• The project also proposes to generate power from
solar, which will help alleviate greenhouse gas
emissions and reduce firewood burning for cooking
• The project will generate revenue for the
government. The tax revenues will help provide
services/rebuild respective towns.
• The project will also create jobs for residents.
• The Ministry of Energy's environment department
has drafted environmental guidelines that the
developer could adopt. However, these guidelines
are yet to be passed by parliament.
• The contractors must adopt municipal waste
management systems regarding waste management
especially E-waste.

Department of Federal Ministry of • The developer's plan to supply electricity and clean
Energy Energy and Water cooking technologies is in line with country’s
Resources. strategic energy policies is highly welcomed since it
does not currently have reliable electricity and
efficient cooking technologies.
• Using clean cooking is vital since it will contribute to
mitigating climate change and environmental
protection, while creating opportunities for the poor
who do not have access to necessities.
The state generally does not generate its electricity
and depends upon private electricity suppliers. The
long-term plan is the government to take over the
transmission and distribution which will be beneficial
both to the private sector and the citizens as this
increases efficiency and lowers the cost of energy.

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 Name of
Organization Comments
respondent
Galmudug State State Ministry of • Minsitry welcomes this project as it is in line with state
Energy policy in energy, promotion of clean cooking and use
of renewable energy
• Most residents in project sites lack access to electricity
at affordable prices to support productive uses of
electricity. Thus, once the project is implemented,
residents will have cheap and clean electricity to use it
for commercial activities which will in turn increase the
state and local governments revenues and enhance
the legitimacy of the government.
• Productive use of electricity will also support the
creation of employment in the city, benefitting the
entire community
Promotion of clean cooking technologies will reduce
charcoal burning and overall environmental
degradations and greatly contribute the health of
the citizens.
Puntland Ministry Puntland State • The project will contribute to environmental protection,
of Energy Ministry of Energy, and State will benefit economically [cost savings due
minerals, and water to lower energy tariffs] and from reduced power
resources. outages in Eyl
• Promotion of clean cooking technologies could end the
charcoal burning and reduce environmental
degradation.
• The project can have a great impact on our work
because it will generate government revenue that will
be spent in ways that are especially beneficial for
women.
• Jobs are an opportunity for young men and women
because there are few job opportunities in the country.
Young men and women should be given the
opportunity to live in peace in their country.
• The project should create opportunities for women
especially in office-based roles and those with small
businesses.
• State ministry of energy have a significant role in
implementing projects in all districts. Specifically,
the contractor should ensure that:
a) Women's rights at the workplace are protected
b) Women should not be discriminated against in
the workplace
c) Provides equal employment opportunities
State to make sure contractors follow all country and
state level safeguard laws and regulations
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 Name of
Organization Comments
respondent
Southwest State State Ministry of • The projects align with state ministry's and the
officials Energy of country's aspirations to spur development while
Southwest providing lessons to leaders that will enable quality
States service provision in energy sector
• The project will generate revenue for the government
through taxes and license fees and create employment
in project areas.
• The project will have a multiplier effect for income
generation for local people and promote trade in
clean cooking technologies.
• The project will help to address environmental
problems such as air pollution and the decline of
natural resources which contribute to poor living
conditions and environmental degradation.
• Relevant Ministries need to learn from any policies
and regulations adopted by the federal ministry and
the bank and monitor the contractors’ activities of the
project
• The ministry is currently developing safeguard policies
and standards in line with country laws and regulations.
Hirshabelle State State Ministry • The project will have various benefits including: (1)
of energy contributing to efforts to address climate change (2)
reducing air pollution (3) lowering the price of electricity
(4) attracting additional investment to Barawe and
Southwest State in general.
• The project developer should abide by the
municipal environmental regulations.

Jubaland State State Ministry • The proposed project is in line with the Ministry’s
of energy and objectives to improve infrastructure, protect the
water environment and facilitate the development of
resources Bardhere
• The project will also contribute to developing the
town
• The project developer should ensure that it adheres to
relevant urban, social, and environmental regulations.
The project should ensure quality controls from
construction, operation, and decommissioning

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 Name of
Organization Comments
respondent
District Officials. Bardhere • The project is a welcome addition to the
District Bardheremunicipality infrastructure.
• Infrastructure is beneficial and Bardhre district may
serve as a model for other districts in Jubaland
• Bardhere municipality has a department responsible for
protecting the environment and a director in charge of
waste management. The municipality has its own health
and pollution control, and the developer should adhere
to the following:
a) Dispose of all garbage at designated locations
outside the city.
b) The developer must put in place measures to
protect the environment from harm.
c) The company must be responsible for any
problems in the workplace that might lead to
ecological damage and contamination.
• About employment, the municipality must provide a
letter to casual and permanent staff.
• All companies operating in the district are required
to register with the district.
District Officials Eyl District The project will positively impact the municipality once it is
handed over to the government by increasing tax revenue.
Eyl local administration has had ambitions to have such a
project to improve access to electricity for the community and
promote clean cooking technologies in line with the project
The local must be aware of the preparation of the project prior
to this, and should provide the necessary information, including
design.
Land acquisition should go through the municipal land
department.
District Official Dhusomareb • It is very helpful for Dhusomareb, state capital, to get
District cheaper electricity, promote clean cooking from
developed nations which will help Dhusomareb
develop.
• The project will also protect the environment by
reducing emissions, unlike the conventional diesel
generators.
• The project presents several opportunities:
a) It could potentially supply reliable electricity to key
Dhusomareb infrastructure improving services

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 District Official Jowhar • The project will contribute to supplying Jowhar with
District reliable electricity and promote clean cooking
technologies.
• It could also provide employment opportunities to
vulnerable groups, including internally displaced
persons in Jowhar
• The project will not have negative impacts on
vulnerable groups, including IDP areas.
• The developer could communicate further with
vulnerable groups, including IDP communities
through the regular community health worker
visits and through community mobilization
facilitated by relevant ministries
District Official Barawe • The current electricity distributor has limited capacity.
District Having another source energy will be beneficial and
Administratio greatly reduce the cost of electricity in the city.
n
• The municipality applies the SWS laws. Employees
working at the site will be required to submit letters of
employment to the Barawe administration.
Promotion of clean cooking technologies is in line with
the district goals and ambitions.

Name of
Organization Comments
respondent
Business Business • The proposed project will contribute to lowering of
Representative Community electricity tariffs in the city.
The project will also increase job opportunities and
generate revenue for the government through taxes
and license fees.
NGO Local NGO • The NGO focuses on water sanitation and hygiene
representative (WASH), food security, education, health, nutrition,
protection and vocational training in the country.
• Its target groups include internally displaced persons
(IDP), residents, marginalized communities, vulnerable
people, returnees, and host community. In this,
introduction of clean cooking technologies to the IDPs
will be of great help.
• The proposed project has no negative impact for our
interventions in the community. Rather, it will have a
positive impact because it is being built in an area that is
currently unused and it will bring positive benefits for the
community.
• To have a greater positive impact on the community,
such projects should be expanded to a wider area of the
community and preferably to all districts that are

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 Name of
Organization Comments
respondent
accessible [from a security perspective].
Currently Somalia is in a recovery period and donors are
prioritizing emergency and humanitarian programmes.
Large development and infrastructure projects [such as
this] need commitment from government and
development partners. Donors may be more willing to
commit to long-lasting solutions if the security of their
investment can be guaranteed

International INGO ▪ Somalia has one of the largest IDP populations in the
non- world including many women and girls.
governmental ▪ Camp Coordination and Management Cluster
Organization (CCCM) has been working on solar lighting in IDP
representative communities.
▪ We believe improved lighting and introduction of clean
cooking technologies will reduce GBV risks and increase
safety of women and girls. 40% of violence takes place at
night. Usually, our organization does not construct such
lights, however small portable solar lamps are distributed.
▪ We also work on preventing SEA and on health
services.
We do not think the proposed project will increase exposure
of women and girls to GBV or affect their safety because it is
inside the green zone. It is also far from the IDP sites.
Community Community • The project will create employment opportunities,
Representative group especially during the construction phase. There would
be employment opportunities during the operational
phase as well benefitting residents of project areas
• The proposed project will have minimal adverse
impacts during construction and operation since it
seems well planned. The following strategies could
help the project to have a stronger positive impact
• Community welcomes this project especially bringing
down the cost of electricity and introduction of clean
cooking technologies.
• Communication and participation of the community
should take place in a safe and accessible location
• The contractors should consider undertaking community
awareness programs on the importance of solar power
and clean cooking technologies.

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 Name of
Organization Comments
respondent
• The best way of engaging the community is through
awareness programs, training and participation in the
construction and operation of the project.
• Support the employment of youth and women and use
local traders and companies to promote development.

Community Women’s • Women will benefit in different ways. For example, it will
Representative Group generate income for the individuals hired as manual
2 workers during the construction and operation
especially women headed households and women with
small businesses
• Local women contractor will also benefit the project,
and there will also be a market for suppliers of
construction materials.
• There should be investment in a large-scale power
project that would meet the power needs of the entire
community.
• The developer should continue engaging with and
consulting with women groups and other vulnerable
segments of the community.
• Consider carrying out awareness activities on the
project, building the capacity of women organizations
institutions and further needs assessment of the
community.
• Clean cooking technologies could create a market
that will benefit women
• Access to electricity would be beneficial to women. If
women could use electricity for cooking this could reduce
cooking times and be cheaper.
Women collect firewood from remote areas putting them
at risk of rape. It is possible to reduce the risk of rape with
electricity through solar PV.

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