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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA)
REPORT SUMMARY
FOR THE
ORGANIC SUGAR PROJECT OF PURE DIETS MOZAMBIQUE S.A.
IN
MOZAMBIQUE
0CTOBER 2015
E&S Team: Erika AUER, Senior Social Development Specialist, ONEC3
Kelello NTOAMPE, Environmental Scientist, ONEC3
Sector Director: K. DIALLO
Regional Director: K. MBEKEANI
Resident Representative: J. RIBEIRO
Division Manager: M. CISSE
AFRICAN DEVELOPMENT BANK GROUP
ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) SUMMARY PURELIFE
ORGANIC SUGAR PROJECT
1. INTRODUCTION:
This environmental and social impact assessment summary presents the process, approach, outcomes and
management plan for the Pure Diets Mozambique SA (herein referred as PDMSA) organic sugarcane
cultivation, sugar production and cogeneration (also referred to as ‘cogen’) power plant project proposed at
Malangane, Moamba district Maputo Province in Mozambique. The project is located to the South of the
Inkomati River bank, in Sabie Administrative Post. Moamba is well connected by road and rail. The distance
between Maputo and Moamba is 80 km.
The Pure Life Group is working under the brand “Pure Life” and is operational in several other countries to
shift conventional agriculture practices to organic farming.
Organic farming is a form of agriculture that relies purely on techniques such as green manure, compost, green
harvesting and biological pest control. Organic farming does not uses any chemical, fertilizers or pesticides in
the farming practices. Green manure, bio fertilizers bio pesticides are used in farming that have no adverse
impact on environment or soil fertility. Organic farming is a strategic fundamental choice for the farmer and
PDMSA believes that it is the unique way to ensure a rational and sustainable management of natural
resources.
The Pure Life Group operates as an organic foods supply chain through its 6 major legal entities in 8 countries
with direct access to about 90 boutique corporate consumers / retailers across the world.
As supply chain managers, the Group is involved in the entire farm to fork spectrum from soil preparation to
final dispatch of goods to the end customer. It has a team of technical experts handling each level of the supply
chain; market analysis, product development, research and development, soil preparation, farming, farmer
dialogue and training, production, quality check, food safety, warehousing, dispatch, logistics and distribution.
The Group also collaborates with local agricultural universities in the countries where it has operations to
provide technical support to the farmers. It works with over 22000 farmers and over 79000 ha of farmland,
some of which are under various organic food certification process. As well as one affiliate organic mill also
in India, which is the source of its organic sugar supplies. Pure Life Group also works with farmer groups and
has organic food and feed projects in Vietnam, Mozambique and Latin America (in LatAm projects are at
nascent stage.) It ensures production and supply of organic produce, including sugar, by deeply involving
itself at the grass root level. The company through its team of technical experts in these countries engages in
closely monitoring the produce right from soil preparation and overseeing the farm practices to critically
observing and evaluating every step of the production processing.
Its project development team identifies local farmers willing to learn and convert to organic farming. Through
continuous education and training sessions, Pure Life helps farmers take on organic and Fairtrade practices.
Its experts interact with farmers, test soil and seedlings, monitor farming practice, record relevant data required
for inspections and audits by organic certification bodies, and ensures compliance with the standards. It has
Field Officers trained in imparting knowledge of organic farming.
These experts work with farmers to help them develop farmland and farming activities and practice which
meet organic requirements. Pure Life staff organizes regular trainings at its project sites to ensure that the
farmers are constantly in touch with the latest standards to be followed. It also provides financial support
through distribution of free organic agricultural inputs. The Group has a certification team at its New Delhi
office, which works with projects and farmers across India and elsewhere. The Group’s production team
regularly monitors the production from the perspective of all the standards like food safety, quality assurance,
HACCP, GMP, social and environmental aspects, OSH etc. It ensures that all units have food safety
certifications such as ISO 22000, HACCP, Kosher, and Halal if required.
The Group also has track record working with demanding and varied certification agencies worldwide such
as OneCert, USDA Organic, FDA, Fair Trade, Control Union and EcoCert. The company has in the past
worked with farmers who own their own land, but the company is are closely involved in monitoring farm
production and processing activities. It is this wealth of experience working with local farmers and global
organic standards which the Group’s management brings to PDMSA. The following table provide a brief
overview of Pure Life operations worldwide. The below acreage is totally owned by the farmers, which the
Group works with and trains to promote organic farming. Pure Life Group Projects Overview (Organic Crop Production)
Name of Country No. of Projects No of registered farmers Reg. area (ha)
Tanzania 7 10047 55205.455
Vietnam 7 1361 3575.97
Mozambique 2 2329 8274.35
India 30 8449 12248.717
GRAND TOTAL 46 22186 79304.492
Pure Life Group Projects Overview (Sugar Processing)
Name of Country No. of Projects
Vietnam 5
India 3
PDMSA has proposed to set up new sugar mill of 3500 tonnes of cane per day (TCD) expandable to a 5000
TCD capacity along with a 12 megawatt (MW) capacity co-generation power project for captive consumption.
PDMSA has also proposed to cultivate 4311hectares (ha) of land for organic sugarcane in a phased manner.
An additional 650 ha of land shall be used for setting up necessary infrastructure like factory, roads, housing,
and reservoirs. Out of this 650 ha, 200 ha is reserved for the factory. The power generated by the cogeneration
plant will be utilized for its own consumption and irrigation facilities.
2. PROJECT DESCRIPTION AND JUSTIFICATION:
2.1 Description:
PDMSA proposes to implement the organic sugar production 0.45 to 0.9 million metric tonnes (MMT) of cane
per year and a sugar mill of 3500 TCD capacity expandable to 5000 TCD for 240 days. In addition, PDMSA
will establish a captive cogeneration power plant by end of year 2017. The project will produce sustainable
and organic sugarcane and intends to use innovative agriculture practices to support and enhance soil fertility
while simultaneously fixing organic matter and carbon in the soil and reduce the environmental and social
impacts of the production. Land clearing will be by mechanical methods. Land clearing and preparation will
employ procedures to minimize release of greenhouse gases (GHGs). Cleared biomass will not be burnt but
chipped and ploughed into the soil during land preparation stage or used to produce compost. Larger biomass
will be brought to the plant site and stored for use for producing power during operations.
Irrigation systems will be installed, followed by the planting of the first commercial crop. A variety of
irrigation systems will be used including centre pivots, semi-solid sprinkler and sub-surface drip systems in
order to optimise agricultural yield and ensure efficient water management for the specific soil. The water
rights are issued to all water users based on the water availability and the command area under consideration
by the regional water authority Administração Regional de Águas – South (ARAsul). ARAsul will inspect
and monitor all the water users in the area every month based on the area under irrigation. PDMSA’s irrigation
engineer will monitor the abstraction to ensure compliance with ARAsul requirements. The project will use
water from the Corumana dam, which has water storage capacity is 881 million cubic meters without gates.
The Mozambique government has provided the approval for installation of gates at the dam during 2016 to
2018 to further increase its storage capacity. After installation of gates the estimated storage capacity of the
dam would be 1240 million cubic meters. The command area of the dam for irrigation is 33,000 hectares.
Water rights have been given to various stakeholders for irrigation up to 23,000 ha including PDMSA’s 4311
ha. PDMSA has water rights for 43.11 million cubic meters/ annum. ARAsul authorities have confirmed that
this quantity of water that can be sustainably abstracted and will not have any adverse effect on the water
resources in the area. PDMSA currently has a permit for water usuage, but a more permanent water concession
is being discussed with the government to be provided by July 2016; this permit will be valid for 50 years.
The Mozambique Government has also commenced the construction of Moamba Major dam which is
expected to be completed in 5 years with the same capacity as that of Corumana dam. This would be
advantageous for the project as it will supply water to Maputo city, thereby freeing up water from the
Corumana dam for agricultural and industrial users downstream. The project site located nearer to both the
dams, and hence it has got high assurance of water supplies.
Planting and harvesting of sugar cane will be done using mechanical planters and equipment respectively. In-
field tractor-trailer combination will transport cut sugar cane. Since the sugar content is highest at the base,
cane will be cut as close as possible to the ground. The remaining cut will be the base for new cane growth
(ratoons) in the following season. The crop is typically replanted after 6 to 8 ratoons. During the replanting
phase, minimum tillage techniques will be implemented to minimise the release of GHGs. The replanting
schedule will also allow for a fallow crop.
Mechanical harvesting of the cane will leave a blanket of trash leaves and tops in the fields that gradually
build up the organic matter and carbon content of the soils which, in addition to being a carbon sink, improves
the quality of the soils as well as minimise the growth of weeds.
2.1.1 Sugar Plant Operations Following harvesting, the cut sugar cane is transported within 24 hours to the facility to avoid deterioration of
sugar content. Upon receiving at the processing plant, the sugar cane is mechanically shredded, run through a
diffuser to extract the juice, and separated from the residual fibres (bagasse). The juice is then put through a
clarification and evaporation process. The facility will be designed to be flexible so that some juice can be
sent not only for sugar production but also for production.
The processing plant will be in full operation for eight to nine months, approximately June through February
(approximately 240 effective days per year). During this relatively dry period sugar cane is harvested and
sugar and power shall be produced. Non-operational time shall be used for maintenance of the plant.
Production may be extended to later in the rainy season by storing molasses or by purchasing molasses from
at other estates.
2.1.2 Power Generation The bagasse will be fed into a high pressure boiler to generate steam and electricity. The steam and electricity
shall be used to fully supply the industrial plant and the irrigation system with renewable energy. The facility
is designed for efficient and minimum internal use of steam and power in order to maximise the surplus
electricity that can be sold to the national power grid. The boiler is designed to also be able to utilise secondary
biomass such as wood chips and energy grass as fuel. The boiler flue gas treatment will consist of a filter
system to minimise emissions of harmful compounds. Power will be generated for use during the full year
with exception for a number of weeks required for maintenance of the boiler.
2.1.3 Effluent & Air Pollutant Treatment Facility Effluent waste stream from the industrial plant has got a high chemical oxygen demand and biochemical
oxygen demand makes it a potential hazard to the environment. However, effluent also has high nutrient
value. The effluent and the sewage shall be treated and the high quality recycled water used for landscaping.
Electrostatic precipitation and wet scrubber will be used to treat other polluting gases generated from project
operations.
2.1.4 Utilities & Consumables
Water and power are the main utilities required for operating the integrated project. Water will be drawn from
the Inkomati River flowing on the border of proposed site. Power required for construction and in case of shut
down of plant, will be drawn from the local grid.
2.2 Justification for the Site
The proposed site is ideal for the proposed integrated sugar & cogen power project, due to following reasons:
Required land for cane development is available at the project site on lease for PDMSA.
The site is easily accessible by road, and near to Maputo Port and Maputo International Airport.
The command area has huge potential for the sugar cane because of the huge irrigation potential.
The site is near to the Inkomati River which is flowing close to proposed factory premises.
3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK
The ESIA for the project was carried out under the following Policy, Legal and Administrative Framework:
o The constitution of the Republic of Mozambique in its Article 72 states that "every citizen shall have the
right to live in a balanced environment and the duty to defend" and in Article37 "The State shall promote
efforts to guarantee the ecological balance and the conservation and Preservation of the environment in
order to improve the citizen's quality of life.
o The National Environment Policy (approved by resolution 5/95 of 06 December 1995) reinforced the
reasoning of other environmental legislation. The main objective of the policy is to provide a tool to ensure
that sustainable development can occur, and to allow the use of natural resources in a way that preserves
its operation for future generations.
o The Environmental Law (Law No. 20/97 of 07 October 1997) applies to public and private sectors and
sets the legal basis for the sound use of natural resources in a way that improves the quality of life of
citizens, prioritizes the development of techniques that minimize environmental degradation, emphasizes
public participation, and integrates principles of payment of polluters.
o The legislation of Environmental Impact Assessment (EIA), approved by Decree 45/2004 of 29 September
2004, is applied to all activities of public and private sector. The legislation employs three categories of
environment assessment:
- Category A: is for projects that could potentially have significant impacts due to the nature of the
activity and or environmental sensitivity hosting the project. You are prompted a full EIA.
- Category B: is for projects that would have negative impacts but the extent, intensity and duration are
less, and the impacts can be largely mitigated. It asked for a Simplified Environmental Study.
- Category C: is for projects that have minimal impacts and the completion of an Environmental Impact
Assessment are not required.
3.1 Other pieces of legislation and requirements includes:
Prohibition of grasping of marine foliage of Euchema gender by Portaria (Ministerial Legal
Instrument) no. 23651 of 12 December 1970
Regulation of Port Captainship, approved by Portaria (Ministerial Legal Instrument) n. 1097, of March
20th, 1967
Regulation Relating to the Process of Environmental Auditing, approved by Decree n. 32/2003, of
August 20th
Regulation on Bio-medical Waste Management, approved by Decree n. 8/2004, of February 18th)
Regulation on Environment Quality Standards approved by Decree n. 18/2004 of June 2nd
Environmental Regulation on Mining Activity, approved by Decree n. 26/2004, of August 20th vii)
Regulation on the Process of Environmental Impact Assessment, approved by Decree n. 45/2004, of
September 29th, revokes Decree n. 76/98, of December 29th
Norms of application of fines and other sanctions provided for in environmental legislation, approved
by Ministerial Diploma n. 1/2006
General Waste Management Regulation, approved by Decree n. 13/2006, of June 15th
General Regulation on Marine Fisheries (REPMAR), Decree n. 43/2003, of December 10th
General Aquaculture Regulation, Decree n. 35/2001, of November 13th
Environmental Inspection Regulation, approved by Decree n. 11/2006, of June 15th
Forests and Wildlife Regulation, approved by Decree n. of June 22nd
Land Use Regulation, approved by Decree n. 66/98, of December 8th
Regulation for Industrial Activities Licensing, Decree n. 39/2003, of November 26th
Article 109 – land, Article 110- Enjoyment of Land and Article 111- Rights Acquired Through
Inheritance or Occupation of Land of the constitution of Mozambique
3.2 AfDB Requirements:
The following Operational Safeguards standards have been triggered:
OS1: an Environmental and Social Assessment will have to be carried out in order to determine the
extent of the environmental and social impacts of the project;
OS2: the project and associated project will require involuntary resettlement.
OS3: it is expected that the project will impact the ecosystem service on which the local population
depend in in terms of sustenance, livelihood and/or primary income.
OS4: it is expected that the project will cause adverse environmental and social impact owing to
emission of pollutants and waste or hazardous materials.
OS 5: the project involves the establishment of workforce.
3.3 Relevant International Treaties and Conventions include:
Dates Relevant International and Regional Conventions; 1982
United Nations Convention on the Law of the Sea (UNCLOS) 1992
United Nations Framework Convention on Biological Diversity (CBD) 1973/78
International Convention for the Prevention of Pollution by Ships (MARPOL) 1998
Convention on Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in
International Trade (PIC) 2001
Convention on Persistent Organic Pollutants (POPs) 1972 Convention on the Prevention of Marine
Pollution by Dumping of Wastes and Other Matter (The London Convention) 1997
Convention on the Non Navigational Uses of International Watercourses (Watercourses) 1985 Nairobi
Convention for the Protection, Management and Development of the Marine and Coastal Environment
of the Eastern Africa Region and Its two protocols on SPAW and Emergency in Cases of Oil spills)
1968/2003
African Convention on the Conservation of Nature and Natural Resources(Algiers, Maputo) 1992 UN
Framework Convention on Climate Change (UNFCCC) 1994
UN Convention to Combat Desertification (UNCCD) 1989
Convention on the Control of Trans boundary Movements of Hazardous Wastes and Their Disposal
(Basel) 1991
Convention on the Ban of the Import into Africa and the Control of Trans boundary Movement and
Management of Hazardous Wastes within Africa (Bamako).
Millennium Development Goals
4. DESCRIPTION OF PROJECT ENVIRONMENT
4.1 Latitude & Longitude
The area lies between 25 degree, 20’, and 25 degree 30’, south latitudes and between 32 degree 10’, and 32
degree 30’, east longitudes.
4.2 Rainfall
The months of June, July, August and September are receiving the lowest rain fall in the year and January to
March seems to be highest rainfall receiving months. The rainfall details of the last ten years shows the average
rainfall per year is 603 mm. It is noticed that 2003, 2004, 2005, 2006, 2007 & 2008 received below normal
rainfall while the balance years in the last decade like 2002, 2009, 2010 & 2011 have received above normal
rainfall.
4.3 Temperature & Humidity
January to March high temperature levels of about 310C and July to September have low temperatures of about
130C. The wider difference between the day and night temperature is recorded at over 150C during the months
June to September is giving the highly favourable diurnal variation for the best sugar accumulation in the
sugarcane stalks.
4.4 Evaporation
The average evaporation for the last 10 years is about 1505 mm due to less rainfall and high temperature.
4.5 Relative Humidity
The Relative humidity is seems to be an advantageous factor as the crop can withstand some prolonged
drought with the available irrigation systems. The average relative humidity is 65% in the project area.
4.6 Sunshine hours
On average, there is over 8 hours sunshine in Moamba which will facilitate sugarcane crop with better sugar
accumulation and sugarcane yield.
4.7 Land Use:
Moamba is well connected by road and rail. The distance between Maputo and Moamba is 60 km. An
estimated potential arable land of 229,000 ha in the district of Moamba, with land use pattern as follows:
Area occupied by corporate farms are 33,600 ha (24,500 ha of rain fed and irrigated 9,100 ha)
13000 ha are occupied by family farms with an average holding size of 1.3 ha.
Total area occupied by corporate and family farms are 43,600ha which is 20.3% of total arable land in
Moamba District.
60,000 ha area occupied as pasture for livestock which is 26.2 % of arable land.
Hence balance of 125,400 ha (53.5%) is the potential area available for further development.
The main crops grown for food by most of the population are Maize, cassava, cow peas followed by
sweet potato pea nuts, pumpkins along with vegetables.
4.8 Noise & Air Quality
4.8.1 Daytime Noise Effects
During the daytime (0700 to 2200, total Project noise from operations at the factory site ,plus baseline levels
is predicted to be well below the IFC daytime LAeq standard of 55 dBA at the closest receptor, Malengane
Village. The highest daytime LAeq level (including baseline levels) predicted at Malengane Village (6 km
from factory site), is 27 dBA, which is 28.1 dBA below the IFC daytime noise guideline. Based on the
information above, no exceedances of the daytime IFC guidelines are projected for any of the nearby receptors
within the Study Area (Malengane Village). Therefore, the noise effect of the Malengane Project during the
daytime will be insignificant (low severity; low likelihood). No specific mitigation measures are required
during daytime operations.
4.8.2 Night-time Noise Effects
During the night-time (2200 to 0700), noise from operations at the factory site, plus baseline levels is predicted
to be well below the IFC LAeq standard of 45 dBA at the closest receptor, Malengane Village The highest
night-time LAeq level (including baseline levels) predicted at Malengane Village (6 km from the factory site),
is 26.9 dBA, which is 28.1 dBA below the IFC daytime noise guideline. Based on the information above, no
exceedances of the night-time IFC guidelines are projected for any of the nearby receptors within the Study
Area (Malengane Village). Therefore, the noise effect of the Malengane Project during the night-time will be
insignificant (low severity; low likelihood). No specific mitigation measures are required during night- time
operations.
4.8.3 Transportation Noise Effects
During the operations phase, movement of trucks (i.e., transport of sugarcane and raw sugar) along the
Transport Corridor will result in increased noise levels at nearby receptors along the corridor. Based on
observations there are no receptor within 100 m of the factory. Along the corridor (just based on observation;
no traffic counts or baseline noise levels were taken along the Transport Corridor). The increase in Project-
related truck traffic is expected to increase noise levels along the corridor and as such, result in a moderate
noise impact (low severity; high likelihood). Recommended mitigation measures to control the noise
emissions are listed below.
4.8.4 One of the main sources of air emissions at the project site and which could potentially generate
significant amounts of carbon monoxide (CO) and dust is the burning of open fields which is done as hunting
strategy and also the production of charcoal for domestic use is very common.
4.9 Geology / Geomorphology & Soils
The project is located in ancient alluvial terraces of the Inkomati River with altitudes ranging between 60 and
85 meters. In this region there is basaltic soils or alluvial terraces in the wide of the Inkomati River floodplain,
with a surface layer of organic matter, with a fertility level from medium to high and with a good agricultural
potential. The shape, thickness, and the nature of the layers vary according to the extent and strength of the
floods that gave rise to the sedimentation process. Most of the proposed area is dominated by alluvial soil and
clay being characterized by, deep, well drained with a bulk density of 1.1 to 1.4 g / cm3, total porosity, with
groundwater above 4 to 6 feet deep, with a water retention capacity of 12 to 16%. The pH is between 5.7 &
7.1
4.10 Flora
Typical vegetation of this region is the savanna and thickets of thorny Acacia spp, and species that accumulate
water reserves in the leaves (Euphorbia spp) .These typically occur in shallow soils, reddish, sandy clay. The
occurrence of dense forest is limited to a spot the terrain east, with the notable presence of the Euphorbia
genus. In sandy and shallow soils, the dominance of Acacia genus species are typical in open woods and
alternate with spots with dominance Cobretum spp, occasionally mixed with Terminalia sericea. Associated
woody species include Dichrostachys cinerea, Grewia sp. Euclea natalensis, and African Spyrostachys and
Sclerocarya birrea. The area is covered with grasses as a result of the conversion by human activity, with the
removal of woody component to obtain fuelwood and to open fields for farming and grazing. Much of the
area to be occupied at present for the cultivation of cane sugar had its natural vegetation removed during
colonial times and was converted to grazing areas
4.11 Fauna
In the middle of terrestrial vegetation, it is normal to experience insects, including beetles, mantis, dragonflies,
butterflies, moths, flies, ants, bees, wasps, as well as a variety of scorpions and spiders. Larger animals
currently exist, only rats and snakes. Due to the proximity of the Inkomati River, in the north land area, we
found the presence of gallery forest along their banks constituted by Acacia xanthophloea and Ficus Capri
folia showing up sometimes reclinata Phoenix palm tree and the reed Phragmitis communist. Large mammals
have not been spotted at the project site but next to the River Inkomati, mammalian species associated with
riparian habitats have been observed. These include water ichneumon (Atilax paludinosus), the otter (Aonix
capensis) and the mouse sugarcane (Thryonomys swuinderanus). In the very bed of the Inkomati River or on
its banks the lizard Nile (Varanus niloticus) and the Nile crocodile (Crocodile niloticus) were observed and
nest on the river bank.
In terms of fish fauna, according to Jubb (1967) and Skelton (2001), River Inkomati there is about 50 species
of fish. Most of these fish species make seasonal migrations to side tributaries, wetlands, and floodplains for
breeding. On the other hand, Anguilla marmorata, Anguilla bengalensis labiata, Anguilla, Mozambican and
Anguilla bicolor which go to the sea for reproduction purposes also occur.
4.12 Hydrology
Moamba and the area where it is to implement the draft organic production of cane sugar, is located about a
hundred meters from the Inkomati the bed, which is the main supplier of water. This Inkomati River rises to
about 2000 m altitude in the plateau and mountainous area west of the basin. The Inkomati River Basin has
an area of 46,700 square kilometers and is shared by South Africa, Swaziland and Mozambique. About 33.4%
of the basin lies in Mozambique and is below 200 m elevation, essentially a flood plain lying east of the
Lebombo mountain range. The main tributaries of this river are the Komati, the Crocodile and the Sabie. 80%
of the total flow, occurs between the months of November and March.
4.13 Baseline details about Socio Economic status
In 2007 the District of Moamba, had 56,559 inhabitants. The projections of the National Institute of Statistics,
estimate a population of 68,231 individuals in 2015. A population with a sex ratio of 93 means that the
population is affected by male emigration movement. Reasons include close proximity to the border with
South African Republic and Swaziland. Moreover, there are no employment opportunities.
4.14 Education Levels
51% people of 5 years or more (predominantly men) attend or have already attended primary school. The
highest range of access to schools have been noted in the age group of 10 to 14 years (64%) and being followed
by the age group of 5 to 9 years. This reflects that majority of the rural children take late entry to the school.
The majority of these children who attend primary education are boys. This is primarily due to the inadequate
or non-existent school network teachers in the district.
4.15 Housing, Electricity and Sanitation
The district of Moamba has 10,602 houses out of which around 80% are made from straw or other locally
available material. ~12% are apartments or constructed houses and ~8 % are made from Zinc and wood. ~22%
of the household have municipal water connection and ~57% of the population has access to sanitation
facilities. However, good quality facility is consolidated only in the areas where people have apartments or
house. The population in the proposed project area has got very limited sanitation facilities.
Power is on the national EDM power distribution system which is present in the town of Moamba. The
direction of the current project is in coordination with the EDM and has already made the extension of the
power grid to the project area. The availability of electricity is a major problem in the area with only 13% of
the total population having access to regular supply of electricity. Around 41% of the population has access
to radio and the number is expected to increase drastically due rapid increase in utilization of mobile phones
in the area.
4.16 Drinking Water Availability
With regards to the sources of supply of water, 40% of the people use water directly from rivers or lakes and
27% from the well or holes. Most of the available existing water supply schemes have quality problems. As a
result, many people who use unclean sources suffer from water borne diseases.
4.17 Livelihoods
Most of the people practice rudimentary subsistence agriculture, rearing goats and chickens. Some families
have small stalls and trade various commodities. Some people are involved in in logging, selling firewood or
producing charcoal.
4.18 Conflict Resolution Process
The conflicts within the community are generally resolved within the purview of law. In case of any conflict
within the community the following are approached in the following order:
- Village Authority (Approved by Government)
- Local Authority
- Forum of Local Leaders (Approved by Communities)
- Administrative Level
- Provincial Levels
- National Level
4.19 Health Facilities, HIV and Vector Diseases
Most illnesses are communicable, directly or indirectly, and are related to lack of adequate and safe drinking
water supplies and sanitation, low living standards and poor nutrition. Waterborne and vector borne diseases
are also prevalent in the area. The prevalent diseases in the project area include malaria, intestinal parasites,
diarrhoea, etc. Most of these diseases are not only causes of illness and suffering but also hospitalization.
Malaria has the most victims followed by diseases such as HIV/AIDS, diarrhoea, measles, pneumonia, TB
and typhoid. Malnutrition is prevalent and observable, especially, among the people in the age group of 5-10
years. More services for the prevention, control and cure of infectious diseases, particularly vector-borne ones,
are required. Based on preliminary field assessment, it has been possible to identify the following problems
associated with health service system:
- Health institutions are limited and hardly ever located in rural areas.
- Lack of qualified health staff
- Inadequate supply of drugs and equipment
- Budgetary constraints
4.20 Cultural Resources
The project surroundings have been investigated in terms of religious and cultural site and archaeological
importance. There are no World Heritage listed sites or recorded archaeological sites in the project area.
Tsonga language (Tsonga) and Portuguese are the main languages in this region. The main ethnic group is
Tsonga and a wide range of religious groups exist in the study area with significant proportion of followers.
Major religions practiced in the project area are Christianity (67.6%) and traditional religions (22.9%).
5. PROJECT ALTERNATIVES
5.1 The assessment of alternatives considered alternative in five categories:
Demand alternatives (e.g. producing only rather than developing the proposed project area for edible
sugar production, applying less developed power generation concepts, which generate significantly
less power to the local grid, locating the project site to a different area in the district, region or nation);
Process alternatives (e.g. re-use of waste material, the use of other technologies);
Schedule alternatives (e.g. restricting construction or operations to a certain time of year).
Input alternatives (e.g. use of other raw materials)
Scale alternatives (e.g. changing the scale of the proposed development in order to comply with
environmental and social requirements).
5.2 A range of systematic methods was used to compare and evaluate the various alternatives including
checklists, overlay maps, matrices etc. The following economic, environmental and social aspects were
considered while selecting this site:
- The site is located in upland area with excellent gravitation drainage system (indicated in water
management plan) and hence there is absolutely no risk of flooding and damage to the crop. It was
observed that the other sugar plantation located in low land areas have the risk of flood and crop
damage and hence incurring the economic loss.
- The land in this project area is not used for doing any agricultural activity and as per government
records it’s a bushy land. Hence redeveloping the land for sugarcane plantation will not result into any
loss of agricultural income.
- There is sufficient availability of water for irrigation (as indicated by ARAsul post consultation with
downstream users and regular monitoring of water levels) and hence scarcity of water for irrigation
purpose is not envisaged.
- Due to the upcoming Moamba Dam the water security will be even more strengthened.
- The area is scarcely populated hence there will be negligible disruption with the population habitat.
- There are no world heritage sites, archaeological sites and sacred sites within the project area and
hence no loss to the cultural heritage is envisaged.
- The community in the vicinity of the site have very limited socio economic resources, the project
would make positive impacts on their lives in terms of employment, Medical facilities, education,
sanitation and drinking water facilities etc.
- The access roads to this area are either not available or damaged, the project would help in developing
access roads thereby improvising economic activities and increasing income generation operations.
- A railway line is proposed to be developed on the eastern side of the project area thereby providing
logistic support to the project.
- Maputo International Airport and Port are just 90kms away thereby providing the logistic support and
enhanced economic mobility.
- Availability of sufficient local workforce to cater the needs of plantation activities, project would
generate sufficient employment in the area.
- The soil conditions and climate is highly conducive for sugarcane plantation.
5.3 No Project Alternative
If the project is not undertaken and if the currently land use were to continue the remaining pockets of valuable
biodiversity currently in the area would in all likelihood be decimated by the rapidly increasing unsustainable
charcoal making, releasing comparatively great amounts of carbon to the atmosphere. The project’s public
benefits such as increased revenue to the government, improved infrastructure, introduction of a new cash
crop and thousands of employment opportunities would not be realised. The No Project Alternative would
also aggravate the poor socio economic conditions of the community.
5.4 Site Alternatives
The project is the one of the largest organic sugar project taken up in a planned manner in Mozambique. The
project site was selected due to proximity to Maputo Airport and Maputo Port, access to infrastructure, land
ownership structure and the existence of surrounding villages that are willing to participate in the project.
After discussions with Government of Mozambique and other relevant stakeholders the company was advised
to develop this project in Malangane.
5.5 Technology Alternatives
The technology of the operation of a large-scale sugar cane plantation is well established in Mozambique.
However the technology of utilising modern irrigation systems and processing sugar cane into sugar and power
is well established in neighbouring South Africa, Brazil and India where the process technology providers are
coming from. Therefore, the risk of uncertainty in functionality from establishing the chosen technologies is
minimal.
6. POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS
6.1 Summary of Negative Impacts Construction Phase
- Change in population level due to influx of workers and labourers causing pressure to social services,
food and facilities
- Soil erosion due to runoff effects and loosened top soil during ploughing and planting
- Changes in the quality of surface water due to various pollutants
- Changes in the level of crime due to increased number of people in the area
- Increase in the risk of communicable diseases (e.g. HIV/AIDS) and human health due to increased
population of workers and social interactions
- Change in the level of traffic intensity and traffic accidents due to increased number of vehicles
concurrently with better transport facilities
- Loss in the village workforce to the project
- Loss of biodiversity during clearing and establishment of the plantation
- Fair compensation for land and other properties to be affected by the project
6.2 Summary of Negative Impacts Operational Phase
- Localised changes in surface and groundwater hydrology due to the project activities notably
irrigation.
- Changes in the quality of surface and groundwater due to waste and other pollutants
- Potential interference with migration routes of animals
- Increase in the level of crime due to increase in population in the area
- Interference with aquatic ecology
- Increase in the risk of communicable diseases and human health due to increased population of workers
and social interactions
- Increase in population due to influx of workers and labourers increasing pressure to social services,
food and facilities
- Increase in the volume of traffic intensity and traffic accidents due to project activities concurrently
with better transport facilities.
- Increase in income in the village will lead to youth resorting to prostitution, drinking and loss of
morality
- Increased resource use conflicts, particularly land and water
- Loss in the village workforce to the project.
- Loss of access to the natural resources found at the barren project area e.g. for grazing, hunting
(poaching) and charcoal making
- Gas emissions
6.3 Summary of Negative Impact Decommissioning Phase
- Soil erosion due to run off effects and loosened top soil due the removal of sugar cane
- Loss of employment and income to workers, local economy and the nation
- Change in life style and quality of workers due to loss of employment
6.4 Summary of Positive Impacts of Project
- Employment generation for the Community
- Economic development of the community
- Community will get access to better education facility
- Community will get access to medical facility
- Community will get access to safe drinking water
- Community will get access to better housing, sanitation facility
- Community will get access to public infrastructure
- Community will get financial inclusion through ATMs and Bank Branch
7. MITIGATION:
7.1 Climate and Air Quality
Dust suppression as needed, i.e., watering disturbed areas during dry and windy conditions;
Use of new bagasse and trash-fired Cogeneration Plant with high energy efficiency boilers;
Regular maintenance of the boilers and all equipment;
Installation of emission reduction systems, such as wet scrubbers or electrostatic precipitator (ESP)
technology, on the boilers.
Climate Risk Assessment and Development of Adaption Plan.
7.2 Greenhouse Gases
Ensure densification of vegetation on fringes of cultivated lands
Location of factory at the center of the Project Area to minimize traveling distance for trucks transporting
cane to factory and ultimately minimizing diesel consumption;
Use of bagasse (90 percent) and non-hazardous waste (9 percent) as fuel for the Cogeneration power plant
boilers to produce onsite power and heat requirements (renewable fuel);
Transport of concentrated vinasse to cane field for reuse as fertilizer;
Facilitate the planting of trees and other afforestation to offset loss associated with cleared areas;
Ensure use of well maintained, high efficiency diesel motors for the portable irrigation pumps and mobile
drainage pumps;
Ensure use of energy efficient lighting, heating, and ventilation at factory site;
Where feasible, practice no till and/or minimum till at planting;
Ensure maximum efficiency of tractor passes per hectare during cultivation and crop maintenance;
Ensure precision application of synthetic nitrogen;
Ensure maximum energy efficiency of the conversion process ( and raw sugar production); and
Ensure adequate maintenance of all transport vehicles.
7.3 Noise
Regular maintenance of all trucks in accordance with manufacturer’s specifications;
Install sound suppressive devices (such as mufflers) on the trucks;
Educate truck drivers and ensure they do not exceed a speed limit of 50 km along densely populated areas
along the corridor.
Deployment of acoustic chambers wherever necessary
7.4 Geology, Topography, and Soils
Implement soil erosion, storm water runoff, and sediment control measures, including the use of
appropriate best management practices during clearance activities.
include clearing only small tracks of land at one time and minimizing the length of time that the cleared
areas for industrial use are void of vegetation or for agriculture use not under active cultivation;
Schedule the majority of the construction and land preparation activities, to the extent practicable, to occur
in the dry season and when land has been appropriately drained, or by limiting off-road access, and by
implementing an awareness education and training program;
Use of improved equipment, such as chain drags between bulldozers and the use of root rakes, floating
blades, and careful/knowledgeable equipment operators;
Spill control will be exercised by inspecting equipment, hiring trained and dedicated feelers and
implementing a Spill Prevention and Countermeasures Plan (SPCC). The SPCC Plan describes measures
to be implemented by PDMSA and its contractors to prevent, and if necessary, contain and control
inadvertent spill of hazardous material such as fuels, lubricants, and chemicals, containment walls, and
other measures. In addition, a training module will be developed to educate employees on the SPCC Plan.
7.5 Biological Resources
7.5.1 Terrestrial Biological Resources
The following measures are recommended to mitigate potential biological resources impacts:
Rehabilitation of the Project Area once the Project is concluded;
Include a 50-90 meter wide buffer area Inkomati River to preserves a band of natural, seasonally
flooded habitat within the most species rich and diverse habitats;
Containment of oil, fuel, and chemicals with bunds or similar devices;
A Spill Management Plan will be developed and implemented, which will contain specific measures for
safe handling and storage of hazardous materials;
Enforcement of speed limits on roads to minimize vehicular collisions with wildlife and driver education
trainings to reduce wildlife injury and mortality;
Worker education on the species of concern in the area and how to avoid impacting them; and
Maintain corridors to allow for movement of large mammals.
7.5.2 Aquatic Biological Resources
Creation of a 50-90 meter wide buffer zone along Inkomati River that preserves a band of natural, seasonally
flooded habitat for the aquatic fauna
7.6 Social Economical & Cultural Resources
Completion of archaeological field surveys in previously undisturbed portions of the Project site;
Establishing a Chance/accidental Find Program and training for Project managers and workers; and
Maintaining flexibility in final Project design to protect any unanticipated finds.
8. MONITORING PLAN
SL#
Action Plan Budget
in USD
Timeline/
Frequency
1 Purchase of High Volume Air Sampler for Air Quality (PM10, NOx, SOx, CO),
Noise ,Water Quality and Soil Quality Monitoring Equipment for carrying out
monthly in-house monitoring
15000 Jan 2015
2 In house Air Quality & Noise Level Monitoring 50000 Fortnightly
3 In house Effluent Quality Monitoring 80000 Weekly
SL#
Action Plan Budget
in USD
Timeline/
Frequency
4 Annual Monitoring of the Air Quality, Water Quality, Noise Levels and Soil
Quality parameters by third party laboratory
30000 Annually
5 Conducting Workshop- Worker Health & Safety Management 50000 Quarterly
6 Purchase of Applicable Personnel Protective Equipment for In-house Staff 75000 Annually
7 Purchase of Fire Fighting Equipment’s for Project office- Class A B C as
applicable
20000 Annually
8 Comprehensive Capacity Building Program for 2 Safety Engineers 10000 Mar 2016
9 Appointment of dedicated HSE Manager 90000 Jan 2016
10 Health and Safety Training of EPC Contractor 80000 Quarterly
11 Development and Implementation of ISO 14001:2004 and OHSAS18001:2007
Management System -For Pure Diets Mozambique SA
30000 Feb 2016
12 Developing and Implementing EPC Contractor HSE & Social Guidelines for
Man, Material or Machinery Contract
15000 Dec 2015
13 EPC Contractor Monitoring - health Safety Environment & Social Compliance -
Annual Reporting by Third Party
60000 Annually
14 Developing and Implementing Social Accountability SA8000:2008 Management
System
17000 Mar 2016
15 Developing GHG Accounting System Framework as per WRI
Guidelines/ISO14064 SCOPE 1 & SCOPE 2
55000 Aug 2016
16 Developing and Implementing Global Reporting Initiative Framework GRI 4- to
Report Pure Deits Annual Performance of Sustainability, Environmental &
Social Issues to ALL THE LENDERS & Stakeholders
105000 Annually
17 Conducting HIV/AIDS & vector Diseases Awareness Program for Community 20000 Quarterly
18 Conducting Community Perception Survey on E&S, Economic Aspects 50000 Annually
19 Independent E&S audit- annual basis as suggested by lender group 80000 Annually
20 Climate Adaptation studies 50000 Oct 2016
21 Surface and Ground water Hydrology Modelling 40000 Dec 2016
22 Implementation and Training of the E&S management plans (Already
Developed):
- Construction Environmental Management ;
- Worker Health and Safety Management;
- Biodiversity Management;
- Catchment Management;
- Waste Management, Reuse and Recycle;
- Worker Health and Safety Plan
- Labour Housing Plan
180000 Project
Cycle
Total (in USD) 1 202 000.00
9. CONSULTATIONS
Consultation were held with communities, Project Affected People (PAP), community leaders, local officials
& the district administrator on 7 December 2011 and on 23 September 2013 to ensure that all people are
included in the discussions, a total of 120 people in total attended the meetings. The objective of the meetings
were:
- To give PAPs a chance to have a say and express their views in the planning and implementation of the
project that affect them directly.
- For PDSA to understand the community needs in order to design relevant and sustainable income
generating activities for the community.
- To discuss the social value from the project (like school, employment, enhanced medical facilities, overall
economic development, stabilized livelihood, Initiatives for HIV/AIDS, vector diseases, Women Health
issues, Cattle Management, Drinking water and Food Security
- To inform local authorities of the impacts, agree on a cut-off date, solicit their views on the project and
discuss their share of the responsibility for the smooth functioning of the overall project operations.
Further consultations were carried out with the following stakeholders:
- District Administrator of Moamba
- Malengane Community
- Gowane Community
- Mwamongolonbi Community
- Mwamayanga Communities
Key concerns raised by communities mostly were focussed on how the project will benefit them. Specific
issues pertained to financial benefits once the project starts making profit, Job creation, irrigation of their own
farming areas, development of other areas for agricultural purposes by the community and provision of
alternative grazing land. In turn PDSA promised, provision of schools, development of access roads and
improvement of transport facilities, electricity supply for the area, development of health facilities, provision
of clean drinking water, vocational training facilities, special assistance to people from vulnerable groups such
as old people, people with disabilities, medically incapacitated people, assisting in developing community
centers and places of worship.
The concerns expressed were captured in a MoU which was signed between the communities Malengane,
Mwamungolombi and Mwamanhanga, the District Administrator and Pure Diets Mozambqiue SA on 18
October 2013. However, as the project progressed, PDMSA has not managed to fulfil all of the actions as
committed to in the MoU in the planned timeframe such as construction of water tanks and water lines,
construction of class room in two communities, construction of health centres, completion of electrical
transmission lines and this has led to some concern among the community members and if not addressed
adequately may lead to mistrust within the communities against the project. The main causes for the delays
are due to challenges faced by PDMSA such as change in the project’s management structure, change in the
community relationship team, and delay in mobilization of funds.
Nonetheless, PDMSA has now made some progress in terms of construction of temporary housing for PAPs
(to be completed by October 2015) and providing employment to the PAPs. The permanent housing
arrangement shall be completed within six months of temporary housing. PDMSA shall ensure the socio
economic development of the PAPs as per the requirement of regulations for the resettlement process resulting
from economic activities decree 31/2012 of 8 August Article 1- 28.
PDMSA has identified the following community activities to be completed on priority basis:
1 Ploughing Community Lands Ongoing- To be Completed by Nov 2015
2 Construction of 2 class room in Mwamayanga school To be Completed by Aug 2016
3 Construction of 1 class room in Mwamungolombi
school
To be Completed by Aug 2016
4 Construction of Water Tank in Mwamungolombi To be Completed by June 2016
5 Technical Training Programme for Youth
To be started from Jan 2016- Continual
Basis
6 Awareness programme on HIV / AIDS, Vector
diseases
To be started from March 2016- Monthly
Basis
7 Awareness programme on Women Health
To be started from March 2016- Monthly
Basis
8 Construction of Community Water Tanks Ongoing-To be Completed by April 2016
In order to ensure that corrective measures are taken, PDMSA has developed a Community Engagement Plan
(CEP) which lists all of the committed to activities as per the MoU as well as additional social development
activities that have not been included in the MoU but that will be undertaken as a result of the project. These
activities will be tracked with a completion timeline and progress update and PDMSA will be required to
report on the progress to the lenders on a regular basis.
10. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)
Standard operating procedure along with high quality pollution control equipment/plants shall be put in place
for managing environmental resources. Furthermore, environmental management plans have been
developed/proposed for the project to ensure appropriate procedures are in place to mitigate the negative
impacts identified in the ESIA. As part of the programme, specific control plans have been developed or
proposed for the following:
- Construction Environmental Management ;
- Worker Health and Safety Management;
- Biodiversity Management;
- Catchment Management;
- Speciality Study – Air Quality & Noise Modelling, Hydrological and Climate Studies;
- Environmental Monitoring Plans
- Waste Management, Reuse and Recycle;
- Carbon Emission/GHG Accounting;
- Environmental Pollution Control Equipment
- Archaeological and Historical Management;
- Community Engagement and CSR Management Plan
- Worker Health and Safety Plan
- Labour Housing Plan
- Traffic Risk and Safety Plan
- PDMS- Internal Regulation (Defining employment conditions and labour regulation)
- Approved by Government of Mozambique
(See Annexure for ESMP)
11. CONCLUSION
The negative environmental impacts that may result from the execution of this project can all be managed
through implementation of the ESMP (below).
12. CONTACTS:
1. Kelello Ntoampe, Environmental Scientist; Email: k.ntoampe@afdb.org; Ttel: +22520262708
2. Erika Auer, Senior Social Development Specialist. Email: e.auer@afdb.org; Tel.: +225 2026 2269.
Annex 1: Environmental and Social Management and Monitoring Plan
Aspect, Potential
Impact/Issue
Actions to Mitigate Impacts Responsible Parties Means of Verification That
Commitment Has Been Met
Training/Resources
Required
Schedule for
Implementation
Related Plans
1. Construction Phase: Development of Sugarcane Plantation
Air Quality: Dust and GHG
emissions from land clearing, land
conversion (change in carbon
stocks) and planting activities.
o Dust suppression as needed, i.e.
watering disturbed areas during
dry and windy conditions;
o Ensure densification of vegetation
on fringes of cultivated lands (i.e.
Un-cleared forested area);
o Facilitate the planting of trees and
other afforestation to offset loss
associated with cleared areas;
o Avoid clearing trees which are in
a mature or climax state;
o Where feasible, practice no till
and/or minimum till at planting
Construction contractors supervised by
PDMSA’s HSE Team (to conduct visual
inspections);
Air Quality monitoring
program;
Daily visual inspections during
land clearing are done so that
vegetation remains dense along
fringes of cultivated land and
matured trees.
If necessary, consultant to
implement Air Quality
Monitoring program;
Training of construction
contractors with respect to
which vegetation and trees
should not be cleared and
where to use no till or use
minimum till planting
techniques
Air Quality Monitoring
Program to be carried out
over the entire construction
phase with daily readings of
dust emissions;
One time calculation of
expected GHG emissions
prior to clearing
Activities. Quarterly
monitoring of GHG.
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Soils: Erosion and sedimentation
from land preparation for new
agricultural and renovation of
existing fields for the sugarcane
plantation (vegetation clearance
and grubbing, ditch/drain
construction and canal
rehabilitation and expansion,
landscape grading and re-
contouring to ensure proper
drainage)
o Implement soil erosion, storm
water runoff and sediment control
measures, including the use of
appropriate best management
practices during clearance
activities. Best management
practices can include clearing
only small tracks of land at one
time and minimizing the length of
time that the cleared areas for
industrial use are void of
vegetation or for agriculture use
not under active cultivation;
o Schedule the majority of the
construction and land preparation
activities, to the extent
practicable, to occur in the dry
season and when land has been
appropriately drained, or by
Construction contractors are supervised by
PDMSA’s HSE Team; best practice forest
management enforced by relevant national
agencies;
PDMSA’s staff in charge of logistics to
schedule construction activities during
preferred times.
Awareness related education and training
program to be implemented by PDMSA’s
HSE Team.
Daily visual inspections during
vegetation clearance and
grubbing, ditch/drain
construction and canal
rehabilitation, landscape
grading and re-contouring to
ensure that erosion
and sedimentation are
minimized by construction
contractors.
Training of construction
contractors on soil erosion,
storm water runoff and
sedimentation control
measures (i.e. clearing small
tracks)
Training to be
conducted prior to earth
movement/land
clearing activities
Daily visual inspections to
be carried out during periods
of significant land
preparation
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
limiting off-road access and by
implementing an awareness
education and training program;
Water Quality: Impacts on
Surface water quality
o Protect all areas susceptible to
erosion by installing necessary
temporary and permanent
drainage works as soon as
possible and by taking any other
measures necessary to prevent
storm water from concentrating in
streams and scouring slopes and
steep banks.
Construction contractors are supervised by
PDMSA’s HSE Team; best practice forest
management enforced by relevant national
agencies
PDMSA’s staff in charge of logistics to
schedule construction activities during
preferred times.
Awareness related education and training
program to be implemented by PDMSA’s
HSE Team.
Daily visual inspections during
vegetation clearance and
grubbing, ditch/drain
construction and canal
rehabilitation, landscape
grading and re-contouring to
ensure that erosion
and sedimentation are
minimized by construction
contractors
Training of construction
contractors on soil erosion,
storm water runoff and
sedimentation control
measures (i.e. clearing small
tracks)
Training to be
conducted prior to earth
movement/land
clearing activities
Daily visual inspections to
be carried out during periods
of significant land
preparation
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Water Quality: Increases in
turbidity and salinity in surface
water from releases of turbid water
due to the physical disturbance of
soil during earthmoving activities,
brackish discharges from saline
soils disturbed by earthmoving and
acidic drainage from pseudo-acid
sulphate soils in the north block.
o Any runnels or erosion channels
developed during the construction
or maintenance period shall be
backfilled and compacted and the
areas restored to a proper
condition similar to the condition
before the erosion occurrence
o Prevent storm water damage, the
increase in storm water runoff
resulting from the construction
activities must be estimated and
the drainage system accessed
accordingly.
Construction contractors are supervised by
PDMSA’s HSE Team; best practice forest
management enforced by relevant national
agencies
PDMSA’s staff in charge of logistics to
schedule construction activities during
preferred times.
Awareness related education and training
program to be implemented by PDMSA’s
HSE Team.
Daily visual inspections during
vegetation clearance and
grubbing, ditch/drain
construction and canal
rehabilitation, landscape
grading and re-contouring to
ensure that erosion
and sedimentation are
minimized by construction
contractors
Training of construction
contractors on soil erosion,
storm water runoff and
sedimentation control
measures (i.e. clearing small
tracks)
Training to be
conducted prior to earth
movement/land
clearing activities
Daily visual inspections to
be carried out during periods
of significant land
preparation
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Terrestrial Biological Resources:
The permanent loss of the MFM,
SSMFP, MHFS, SWE and SWP
habitats
o Include a 50-100 meter wide
buffer area along the Inkomati
River to preserve a band of
natural, seasonally flooded habitat
within the most species rich and
diverse habitats.
PDMSA to ensure buffer is maintained
during construction; biological resource
management enforced by LAW and
overseen by conservation institutions.
Periodic visual inspections to
ensure buffer is being properly
maintained during land clearing
activities.
Training of construction
contractors with respect to
the buffer area that should
be maintained and the
importance of this buffer
Training to be
conducted prior to earth
movement/land
clearing activities and
refreshed bi-annually
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
Terrestrial Biological Resources: Habitat degradation from
Hazardous Material Spills
o Containment of oil, fuel and
chemicals with bunds or similar
devices.
o A Spill Management Plan will be
developed and implemented,
which will contain specific
measures for safe handling and
storage of hazardous materials.
PDMSA’s HSE Team and Construction
contractors supervised by PDMSA; proper
management of hazardous materials
enforced by LAW
Periodic visual inspections to
ensure proper management and
handling of hazardous
materials; any evidence of
significant spills or poor
management to be
photographed and logged in an
HSE database
Training of construction
contractors and PDMSA
employees on management
of hazardous materials and
Spill Prevention and
Countermeasures (SPCC)
Plan
Training to be conducted
prior to use of hazardous
materials and refreshed
quarterly
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
Terrestrial Biological Resources: Mortality, disturbance,
displacement, or injury to wildlife
caused by vehicular traffic,
construction equipment,
construction workers and the loss
of habitat.
o Enforcement of speed limits on
roads to minimize vehicular
collisions with wildlife and driver
education trainings to reduce
wildlife injury and mortality;
o Worker education on the species
of concern in the area and how to
avoid impacting them;
o Maintain corridors to allow
movement of large mammals.
PDMSA to coordinate with local authorities
to enforce speed limits
PDMSA to implement driver education
program, emphasizing the importance of
obeying traffic laws
PDMSA’s HSE Team to implement training
on species of concern and mitigating
impacts to those species
PDMSA’s HSE Team (or biologist
contractor) to implement Biodiversity
Monitoring Program which will monitor
migration corridors
Database tracking traffic related
infractions
Documentation of driver and
wildlife management training
provided and attendance
records of those training events
Implementation of Biodiversity
Monitoring Program, which
includes visual inspection of
wildlife corridors and records
signs of disturbance (i.e.
movement into other areas) and
incidences of mortality
Driver safety training to all
workers, including
contractors, who are
expected to drive as part of
their duties.
Integration of a worker
fatigue and stress
management program for
long haul truck drivers.
If necessary, procurement of
expert biologist consultant
to implement Biodiversity
Monitoring program
Training to be conducted
prior to the start of transport
activities or land movement
and refreshed quarterly
Worker fatigue and stress
management program to be
implemented on an on-
going basis but initiated
prior to the start of transport
activities
Biodiversity Monitoring
activities to be conducted
monthly, or as needed,
during construction
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
Terrestrial Biological Resources: Impacts (such as those mentioned
above to general wildlife) to
observed species of concern near
Inkomati River
o See mitigation involving buffer
area and worker education above
as they apply to protecting species
of concern
See above
PDMSA’s HSE Team (or biologist
contractor) to implement Biodiversity
Monitoring Program which will monitor
impacts to species of concern
See above
Implementation of Biodiversity
Monitoring Program, which
includes tracking the presence
of species of concern and
evaluating effectiveness of
mitigation measures to protect
species of concern
See above
If necessary, procurement of
expert biologist consultant
to implement Biodiversity
Monitoring program
Biodiversity Monitoring
activities to be conducted
monthly, or as needed,
during construction
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
Aquatic Resources: Increased
turbidity in the vicinity of the river
o Conduct Canal and other
connected waterway maintenance
activities during periods of high
PDMSA to supervise contractor procured
for maintenance to ensure activities are
conducted during high flow
Supervision of maintenance
activities will confirm the
If necessary, procurement of
consultant to implement
Water Monitoring program
Water Monitoring activities
to be conducted monthly, or
Annexure 25 –P3-
Construction
from suspension of clay when the
irrigation canal is widened.
flow in the Inkomati River, which
would increase dilution potential
downstream of the Canal.
implementation of activities
during periods of high flow.
Water Monitoring Program will
track turbidity levels at mouth
of the Canal
as needed, during
construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan )
Aspect, Potential
Impact/Issue
Actions to Mitigate Impacts Responsible Parties
Means of Verification That
Commitment Has Been Met
Training/Resources
Required
Schedule for
Implementation
Related Plans
Aquatic Resources: Impacts to
aquatic resources as a result of
changes in water quality (DO,
conductivity, pH) mainly from
increased turbidity
o See mitigation measures above
related to erosion and
sedimentation.
PDMSA’s HSE Team (or contractor) to
implement Water Monitoring Program
which will monitor changes in water quality
Water Monitoring Program will
track changes in water quality
both inside and outside of the
Project Area
Biodiversity Monitoring
Program will track changes in
overall presence and condition
of aquatic resources
If necessary, procurement of
consultants to implement
Water and Biodiversity
Monitoring programs
Water and Biodiversity
Monitoring activities to be
conducted monthly, or as
needed during construction
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
2. Construction Phase: Construction of Organic Sugar Production Facility
Air Quality: Dust emissions from
land clearing/ preparation of plant
area, grading of access roads,
excavation and increased vehicle
traffic on unpaved roads
o Dust suppression as needed, i.e.
watering disturbed areas during
dry and windy conditions
Construction contractors supervised by
PDMSA’s HSE Team(to conduct visual
inspections)
Air Quality monitoring program If necessary, procurement of
consultant to implement Air
Quality Monitoring
program
Air Quality Monitoring
Program to be carried out
over the entire construction
phase with daily readings of
dust emissions
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Soil: Erosion and sedimentation
from the construction of the various
industrial facilities.
o See mitigation measures above
for erosion and sedimentation
under “Development of the
sugarcane plantation” as they
apply to the construction of the
processing facility as well
See Above See Above See Above See Above Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
3. Operations Phase: Operation of Sugarcane Plantation
Air Quality: Combustion
emissions (including GHG; CO2,
CH4 and
N2O) from machinery
used for cultivating and harvesting
(non-road mobile diesel engines),
from mobile drainage pumps and
portable irrigation pumps (internal
combustion engines)
o Ensure use of well maintained,
high efficiency diesel motors for
the portable irrigation pumps and
mobile drainage pumps
o Ensure maximum efficiency of
tractor passes per hectare during
cultivation and crop maintenance;
PDMSA responsible for procuring high
quality equipment and overseeing that
operation contractors use and maintain
equipment according to manufacturer’s
specifications and maximize efficiency of
tractor passes
Air Quality monitoring program If necessary, procurement of
consultant to implement Air
Quality Monitoring
program
Training of operation
contractors on maintenance
of motors and pumps,
identifying problems with
equipment and measures for
maximizing efficiency of
tractor passes
Initial investment required
for high efficiency
equipment
Initial selection of high
efficiency motors to be
made during project design
as a result of the alternatives
analysis
Air Quality Monitoring
Program to be implemented
quarterly during operation
Training on equipment
maintenance and tractor
passes to be issued prior to
the operation phase
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Soil: Soil contamination from spills
or leaks of lubricants, fuels and
other chemicals, mainly pesticides
and herbicides that will be used
during the operation of the
plantation.
o Use of improved equipment, such
as chain drags between bulldozers
and the use of root rakes, floating
blades and careful /
knowledgeable equipment
operators
o Spill control will be exercised by
inspecting equipment, hiring
trained and dedicated feelers and
pesticides/herbicides handlers and
by implementing a Spill measures
described measures to be
implemented by PDMSA and its
contractors to prevent and if
PDMSA is responsible for procuring high
quality equipment and overseeing that
operation contractors use and maintain
equipment according to manufacturer’s
specifications
Periodic visual inspections to
ensure adequate spill control
measures are in place and
elements of the SPCC Plan are
generally being implemented
Training of operation
contractors on (i) best
practice use & maintenance
of equipment to reduce soil
contamination from spills;
(ii) management of
hazardous materials and
Spill Prevention and
Countermeasures (SPCC)
Plan; (iii) aerial spraying of
herbicides and pesticides to
minimize application on
sensitive habitats and ensure
best practice handling of
these chemicals
Training to be conducted
prior to the start of operation
and be refreshed as needed
based on results of the
inspections
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
necessary, contain and control
inadvertent spill of hazardous
material such as fuels, lubricants
and pesticides chemicals,
containment walls and other
measures. In addition, a training
module will be developed to
educate employees on the SPCC
Plan;
Terrestrial Biological Resources: Diminished use of habitat by
reducing hiding places and safe
havens for large predators and prey
from the repeated harvesting
activities of the cane crop. The
planting and harvest activities
themselves will disturb the
mammal and bird fauna. The large
mammal fauna will likely move
and retreat into the surrounding
areas.
o Maintain a 50-100 meter buffer
area along the Inkomati River to
allow undisturbed areas for
wildlife.
o Maintaining corridors to allow for
movement of large mammals.
PDMSA to ensure buffer is maintained
during operation; biological resource
management enforced by LAW and
overseen by conservation institutions (e.g.
STINASU, SCF, NCD)
PDMSA’s HSE Team (or biologist
contractor) to implement Biodiversity
Monitoring Program which will monitor
migration corridors
Periodic visual inspections to
ensure buffer is being properly
maintained during planting and
harvesting activities.
Implementation of Biodiversity
Monitoring Program, which
includes visual inspection of
wildlife corridors and records
signs of disturbance (i.e.
movement into other areas) and
incidences of mortality
Training of operation
contractors as to the buffer
area that should be
maintained and the
importance of this buffer
If necessary, procurement of
expert biologist consultant
to implement Biodiversity
Monitoring program
Training to be conducted
prior to planting and
harvesting activities that
may disturb the buffer
Biodiversity Monitoring
activities to be conducted
quarterly, or as needed,
during operation
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
Terrestrial Biological Resources
l: Introduction and/or increase in
rodent populations related to
sugarcane population
o Implement a Rodent Management
Plan including active rodent
trapping and coordination with
local health care providers to
establish procedures to address
any incidence of rodent-borne
disease.
Agricultural Project team lead Regular recordkeeping of
number and location of rodents
trapped
Training of agricultural team
in rodent control and
concerns regarding rodent
infestation for the sugarcane
crop and nearby rice
cultivation.
Monthly monitoring,
quarterly consultation with
local health authorities
regarding incidence of
rodent borne disease in the
Malangane community
Annexure 25 –P3-
Construction
Environmental
Management Plan
PDMSA-
Environmental Policy
Annexure 25 –P6-
Biodiversity
Management Plan
4. Operation Phase: Operation of Organic Sugar Production Facility
Soil: Soil contamination from spills
or leaks of lubricants and fuels and
other chemicals that will be used
during the operation of the plant.
o See first two (2) mitigation
measures above for soil
contamination under “Operation
of the sugarcane plantation” as
See Above See Above See Above See Above Annexure 25 –P3-
Construction
Environmental
Management Plan
they apply as well to the operation
of the processing facility.
PDMSA-
Environmental Policy
Air Quality: Combustion
emissions (including GHG; CO2,
CH4 and N2O) from bagasse and
trash- fired COGENERATION
plant at
o Use of new bagasse and trash-
fired COGENERATION plant
with high energy efficiency
boilers;
o Regular maintenance of the
boilers and all equipment;
PDMSA responsible for installing engineer
controls to reduce combustion emissions
and maximize efficiency of conversion
process. They are also responsible for
researching and implementing
Air Quality Monitoring
Program
Tracking energy use through
electric bills and periodic
visual inspections of work
areas;
If necessary, procurement of
consultant to implement Air
Quality Monitoring program
Training of operation
contractors on maintenance
Initial selection of high
efficiency equipment to be
made during project design
as a result of the alternatives
analysis
Installation of
Electrostatic Precipitator
the factory (boiler stack) and from
on road diesel engines of trucks
transporting cane, raw sugar to and
from the facility.
o Installation of emission reduction
systems such as wet scrubbers on
the boilers.
o Location of factory at the center
of the Project Area to minimize
traveling distance for trucks
transporting cane to factory and
ultimately minimizing diesel
consumption;
o Use of bagasse (90 percent) and
trash (10 percent) as fuel for the
COGENERATION plant boilers
to produce onsite power and heat
requirements (renewable fuel);
o Selling of excess renewable
power (at least 9 MW - base load)
to external fossil-fuelled plant at
the Moamba District;
o Where feasible, implement carbon
emission offsets elsewhere (e.g.
developing the Project as a carbon
development mechanism (CDM)
project and obtaining emission
reduction credits).
o Ensure use of energy efficient
lighting, heating and ventilation at
factory site;
o Ensure adequate maintenance of
all transport vehicles.
carbon emission offsets (to the extent
possible)
PDMSA’s HSE Team (or air quality
contractor) to implement Air Quality
Monitoring Program
Operation contractors supervised by
PDMSA, responsible for maintenance of
equipment according to manufacturer’s
specifications and efficient use of energy
Transport contractors supervised by
PDMSA, responsible for maintenance of
transport vehicles according to
manufacturer’s specifications
energy used in conversion
process to
be evaluated separately
Tracking quantity of excess
renewable power sold to fossil-
fuelled plant at Moamba
District
Documentation of offset
program and emission reduction
credits received
Sporadic emissions testing of
transport vehicles to ensure
adequate maintenance; tracking
maintenance records
of boilers and other
equipment
Training of transport
contractors on maintenance
of transport vehicles
Initial investment required
for high efficiency
equipment
Air Quality Monitoring
Program to be implemented
quarterly during operation
Training on equipment and
vehicle maintenance to be
issued prior to the start of
operation and refreshed as
needed
Energy efficiency to be
monitored over the life of
the Project
Wet Scrubber
High Volume Sampler
for Air Quality
Monitoring
Annexure 26
Environmental Control
Machinery
Specifications
Noise: Movement of trucks (i.e.
transport of raw sugar) along the
Transport Corridor will result in
increased noise levels at nearby
receptors along the corridor (which
includes residences, schools and
houses of worship).
o Regular maintenance of all trucks
in accordance with
manufacturer’s specifications;
o Install sound suppressive devices
(such as mufflers) on the trucks;
o Educate truck drivers and ensure
they do not exceed a speed limit
of 45 km along densely populated
areas along the corridor.
PDMSA responsible for installing engineer
controls to reduce noise emissions
PDMSA’s HSE Team (or noise contractor)
to implement Noise Monitoring Program
Transport contractors, supervised by
PDMSA, responsible for maintenance of
transport vehicles according to
manufacturer’s specifications
PDMSA to implement driver education
program, emphasizing the importance of
obeying traffic laws
Noise Monitoring
Program
Documentation of driver
training provided and
attendance records of those
training events
Database tracking traffic related
infractions
Driver safety training to all
workers, including
contractors, who are
expected to drive as part of
their duties.
If necessary, procurement of
noise consultant to
implement Noise
Monitoring program
Initial selection of
engineering controls to be
made during project design
as a result of the alternatives
analysis
Training to be conducted
prior to the start of transport
activities and refreshed
quarterly
Noise Monitoring activities
to be conducted monthly, or
as needed during operation
Machine Acoustics
Chamber
PPE
Installation of Noise
Monitoring Equipment
Noise: Movement of trucks (i.e.
transport of raw sugar) along the
Transport Corridor will result in
increased noise levels at nearby
receptors along the corridor (which
includes residences, schools and
houses of worship).
o Regular maintenance of all trucks
in accordance with
manufacturer’s specifications;
o Install sound suppressive devices
(such as mufflers) on the trucks;
o Educate truck drivers and ensure
they do not exceed a speed limit
of 45 km along densely populated
areas along the corridor.
PDMSA responsible for installing engineer
controls to reduce noise emissions
PDMSA’s HSE Team (or noise contractor)
to implement Noise Monitoring Program
Transport contractors, supervised by
PDMSA, responsible for maintenance of
transport vehicles according to
manufacturer’s specifications
PDMSA to implement driver education
program, emphasizing the importance of
obeying traffic laws
Noise Monitoring
Program
Documentation of driver
training provided and
attendance records of those
training events
Database tracking traffic related
infractions
Driver safety training to all
workers, including
contractors, who are
expected to drive as part of
their duties.
If necessary, procurement of
noise consultant to
implement Noise
Monitoring program
Initial selection of
engineering controls to be
made during project design
as a result of the alternatives
analysis
Training to be conducted
prior to the start of transport
activities and refreshed
quarterly
Noise Monitoring activities
to be conducted monthly, or
as needed during operation
Machine Acoustics
Chamber
PPE
Installation of Noise
Monitoring Equipment
5. Decommissioning Phase: Closure of Sugarcane Plantation
Retrenchment: Reduction in
workforce during closure period,
with related indirect effects to
secondary economy
o Implement policies and programs
to assist retrenched workers.
Assistance should include career
counselling, training programs
and economic development
opportunities based on level of
skills and type of contract.
-PDMSA HR team to ensure company
policies regarding terms of employment
which may affect retrenchment benefits are
built into employment contracts and
disclosed to workers upon hire.
- Prior to expected retrenchment, PDMSA
HR and CR teams to consult with the
workforce and their representatives and
with local communities where workers live
(Malangane and) to provide information and
Semi-annual monitoring of
retrenched workers, to establish
the outcomes of assistance that
was provided
Records and periodic audits of
reference material, including
written records of consultations
with retrenched workers
Accrual funds necessary to
provide career counselling,
finance retraining and
economic development
program.
Training programs for
retrenched workers should
be established prior to the
closure phase. Based on
consultation with the
community, the training
program should seek to fill
the most pressing skill gaps.
Conceptual Closure
Plan (To be developed
and submitted for lender
review)
receive feedback on the retrenchment
process.
- They should ensure that workforce and
communities are notified of scope, scale and
schedule of anticipated retrenchment in a
timely and suitable manner and are
consulted about options for potential
retraining/economic development/job
placement programs and other support to be
offered
6. Decommissioning Phase: Closure of Organic Sugar Production Facility
No significant impacts associated with the closure of the sugar processing and production facility have been identified
Social/Labour: Project- related
grievances from local communities
or other project-affected
stakeholders
o Upgrade existing PDMSA
Grievance Procedure in line with
international standards
o Consult with local communities
and other stakeholders
communities in project area of
influence) to inform decisions
about the range of options to be
established for receiving and
resolving grievances. Consider
cultural expectations and norms
for communication and problem-
solving related to grievances
o Disclose the grievance
mechanism widely among local
and potentially affected
stakeholders via locally and
culturally appropriate channels
PDMSA Community Relations team, in
coordination with HR team for labour-
related grievances
Ongoing monitoring of
mechanism effectiveness, for
example:
o Number of grievances
received according to
category, per time period
o Number and % closed
according to category, per
time period
o Number of satisfied
responses from
complainants, per
category, per time period
o Identified root causes of
resolved grievances
o Timeframes for closure of
grievances by category
o Repeats of the same
grievance
Training of community
relations staff on the details
of operating the Grievance
Mechanism
Training for all about the
Grievance Mechanism, its
basic elements and what to
do if contacted by a
stakeholder with a project
staff on the compliant
Review and upgrade
(including consultations) of
PDMSA’s existing
grievance procedure to
commence as soon as
possible, prior to
construction
Communicate the Grievance
Mechanism to internal and
external stakeholders by
start of construction and
repeatedly throughout life of
project
Conduct ongoing
monitoring against
established performance
indicators and periodic
reviews of the overall
functioning of the
mechanism and areas for
improvement
Grievance Mechanism
(Stakeholder grievance
management policy)- To
be made available in
local language
Ecosystem Services: The project’s
changes to local hydrology and
ongoing use of water including
o Continue ongoing collaboration
with Ministry of Agriculture and
local water boards in order to: (i)
PDMSA’s Environment team is primarily
responsible for implementing the Water
Management Plan.
Documentation of engagement,
tracking of water-related
grievances
To be Determined To be Determined Continue ongoing
collaboration with
Ministry of Agriculture
water intakes from the Inkomati
river and discharges into the
Inkomati River– will impact
various ecosystem services used by
local and downstream
communities, including water
quality and availability for
domestic and agricultural uses,
fisheries and natural flood
regulation.
Disclose the Project’s Water
Management Plan and
procedures; (ii) Maintain open
communication with other water
users in the Project Area; (iii)
Identify and immediately resolve
any unanticipated negative
impacts to downstream water
users as a result of the Project;
and (iv) Ensure compliance with
local water use regulations and/or
collaborative management
strategies established by the
Ministry.
The Community Relations team should be
involved in all elements related to
stakeholder engagement and information
disclosure.
and local water boards
on water management
issues
Social: Population influx and
associated negative social impacts
due to creation of jobs in
connection with the project
o Establish a Local Content Plan
outlining targets and a program to
achieve them, for number of local
labourers, as deemed appropriate
based on consultations with the
community regarding project-
related benefits for that
community) in each stage of
Project lifecycle;
o Establish, as part of the Local
Content Plan, guidelines to
encourage the procurement of
local goods and services
o In partnership with local
agricultural education
organizations, establish Skills
Training and Development
Program to increase the number
of skilled agricultural workers in
the local Labour market.
For Local Content Plan:
o PDMSA HR team to develop and
implement the plan, including
tracking progress towards hiring and
retention targets for local labourers.
o Procurement team to coordinate with
HR on development and
implementation of guidelines for local
procurement.
For Skills Training and
Development Program:
o PDMSA’s CR team to establish
relationships between the Project and
local agricultural educational
organizations.
o PDMSA’s HR team to develop
training programs to help boost the
capacity of agricultural workers.
For Local Content Plan:
o Actual number of local
labourers employed
versus the target number.
o Establishment and
continuous updating of
database on goods and
services that are available
locally
o Monitoring of percent
value and volume of
locally produced goods
and services procured
For Skills Training and
Development Program:
o Number of graduates of
training courses per
session
o Percent of skills training
program graduates
retained by PDMSA
o Number of participants
and graduates of
programs that adopt new
Implementation of
Technical Skills Training
Program to ensure local
Labour market is qualified
for employment (see below)
Training of human resources
and procurement officers to
guide hiring and
procurement protocols
Development of
partnerships with local
agricultural educational
organizations
Plans to be developed as
soon as possible
Training of HR and
procurement staff on
implementation of Local
Content Plan and Skills
Training and Development
Program as applicable, prior
to initiation of construction
activities and continuing
throughout project lifecycle
as appropriate.
Monthly monitoring and
reporting of actual
performance vs. established
performance indicators.
Yearly monitoring of
agricultural workers who are
trained to ascertain how
their skills or agricultural
practices have changed.
Local Content Program
((To be developed and
submitted for lender
review- Prior to Labour
Mobilization)
Annexure 25-P5-
Community
Engagement & CSR
Plan
PDMSA- OHS Policy
PDMSA- Social
Accountability Policy
technologies or
agricultural methods
Social: Local capacity is
insufficient to staff Project
managerial and technical positions.
Without a program to develop local
capacity and leadership ability, the
Project will remain dependent on
expatriate workers.
o Establish an Internal Leadership
Training and Development
Program to increase capacity of
Mozambican staff and train local
staff in administrative, managerial
and technical positions in order to
replace expatriate positions within
10 years of Project operations.
The PDMSA HR team is responsible for
ensuring that the appropriate training tools
are in place and that the local staff has
access to resources and programs to develop
their job skills and leadership ability.
Number of Mozambican
employees who have received
appropriate training for their
respective and target positions
Percent of those who have
received training (per
subcategory) who have been
hired on full-time in an
administrative, managerial or
technical role
Number of expatriate staff and
their percentage within all
administrative, managerial and
technical project staff
Implementation of an
Internal Leadership Training
and Development Program
to aid the transition from
expatriate workers to local
staff.
If necessary, training of
human resources officers or
employees who will develop
and implement the training
and leadership development
program.
Training should commence
during the operation phase.
Local staff should be given
the opportunity to shadow
expatriate staff and formal
structures should be set up
where local staff can ask
questions to and receive
feedback from expatriate
staff.
Internal Leadership
Training and
Development Program
as CSR Plan
Local Content Program
((To be developed and
submitted for lender
review- Prior to Labour
Mobilization)
Social: Project workers and
contractors will put new demands
on the local housing market in
Malangane and may generate social
conflict and tensions with local
community members, as well as
potentially leading to changes to
local land use due to new housing
construction.
o Evaluate the availability and
quality of existing housing in
Malangane, to determine whether
sufficient adequate housing exists
to accommodate Project-related
influx and to identify any critical
concerns and issues to manage in
association with the housing of
incoming workers.
o Based on evaluation findings,
establish a Worker Housing and
Integration Plan including
procedures and actions to
facilitate the integration of new
staff into Malangane and to dis-
incentivize new land colonization,
especially in areas which may
generate social conflict.
o Specify within the project’s
Labour Management Plan a
company policy on worker
The PDMSA Human Resources (HR) team
will be responsible for ensuring that
behavioural guidelines are in place for
Project workers
The PDMSA Health and Safety team is
responsible for ensuring that appropriate
health and safety provisions are in place for
worker housing. The team should draft
health and safety guidelines that will be
used to monitor the conditions in worker
housing.
The Health and Safety team together with
the Community Relations team is
responsible for the Community Health and
Safety Plan.
Location and quality of worker
housing, including compliance
with health and safety
guidelines,
tenancy information, training
completion
rates on Worker Code of
Conduct, health monitoring and
additional parameters to be
defined in Worker Housing and
Integration Plan and
Community Health and Safety
Plan
Resources should be
available to ensure workers
have access to health-risk
preventive measures, such
as mosquito nets and
contraception, including
condoms.
If necessary, a training
program should be held to
sensitize workers to the
dangers of substance abuse.
If necessary, a training
program should be
established on health and
safety protocols. The
program should be updated
on a semi-annual basis.
Annexure 25-P2 Labour
Housing Plan
Annexure 25-P4 Worker
Health & Safety
management Plan
Annexure 25-P1-
PDMSA Internal
Regulation
PDMSAS Social
Accountability Policy
housing, including a Worker Code
of Conduct for behaviour within
company-owned housing
o Establish a Community Health
and Safety Plan to minimize,
monitor and manage health
impacts to the local community
caused by the influx of what will
likely be a mostly male
workforce.
Social: Expected population influx
related to Project activities will
likely put a strain on existing social
and public services in the area.
o Establish local and regional
planning initiatives in the Project
Area in association with the
community and local authorities.
The initiatives should focus on
improving public service
provision in the project area to
offset the additional burden to
these services caused by in-
migration.
The PDMSA will aid in coordinating the
voluntary activities related to planning
initiatives, including providing advanced
notification of issues related to workforce
and community interaction.
Joint tracking (with local
authorities) of enrolment /
utilization rates of local and
regional social and public
services
Indicators to measure
successful service provision (to
be established)
Accrual funds may be
necessary to finance the
proposed initiatives and
program established.
Consultations should be held
prior to the beginning of
construction to establish
priority initiatives and
services requiring potential
collaboration.
During construction and
operation, planning sessions
should be arranged semi-
annually to determine and
refresh initiatives.
NA
Social: Affected communities and
other stakeholders need to be
informed about and provided the
opportunity to offer views and
opinions on the management of
impacts and risks associated with
the Project. Building trust by
providing opportunities for
stakeholders to be informed and
express their concerns and
suggestions and by taking their
input into account, is an important
component of managing social,
reputational and operational risks.
o Develop a Public Disclosure and
Consultation Plan that establishes
guidelines for consulting and
engaging the local community,
both during project planning and
throughout the life of the project.
The Plan should ensure that
affected groups are notified and
consulted on Project risks,
impacts and other issues that may
affected them. During the Project
lifecycle, affected groups should
be informed about changes to the
Project scope and schedule.
o Within the Public Disclosure and
Consultation Plan, ensure
consideration of the special needs
The PDMSA CR team is responsible for
communicating and engaging with key
stakeholder groups about Project activities
and impacts. They should ensure that
Project communication is accessible and
understandable to different groups of the
affected community and that different
segments of the community are represented
in the consultation process.
Dates, type, nature and
frequency of consultations and
interactions with local
community members and other
stakeholders (tracked by type /
individual)
Responses offered or
commitments made in response
to stakeholder questions and
concerns
Training for CR staff on
implementing the
Public Disclosure and
Consultation Plan
The disclosure and
consultation/engagement
process should be a
constantly evolving process
throughout the Project
lifecycle and should be
periodically updated to
account for changing
stakeholders and Project
information.
Annexure 27-MoU
Commitment with the
Communities
- Local Content
Program ((To be
developed and
submitted for lender
review- Prior to Labour
Mobilization)
-Annexure 25-P5-
Community
Engagement & CSR
Plan
-PDMSA- OHS Policy
-PDMSA- Social
Accountability Policy
and unique characteristics the
community in, as well as other
vulnerable groups in the project
area of influence, to ensure they
have adequate opportunity to
express their opinions and views.
o With respect to, Stakeholder
Engagement should ensure
cultural appropriateness and lead
to Broad Community Support.
Social: Violations of Labour rights,
or inappropriate worker conduct in
local communities, can cause
social, legal and operational risks
to the project, if not effectively
managed. In addition, major
Labour violations (such as
employment of child or forced
labour) among key suppliers may
cause reputational risks to PDMSA.
o Establish a Labour Management
Plan, encompassing the project’s
human resource policies,
procedures and systems to uphold
worker rights in accordance with
applicable national laws,
communicate with and engage
workers and ensure they are
adequately trained and equipped
to perform their jobs in a safe
manner.
o The Plan should include an
Occupational Health and Safety
Program covering all such related
risks to workers. A Worker Code
of Conduct that sets guidelines
and requirements for interactions
between workers and the
community should be included in
the Plan.
o A grievance mechanism should be
in place that allows the project to
address allegations of non-
compliance with established
policies.
PDMSA’s HR team will have primary
responsibility for implementing the Labour
Management Plan.
The HR team should collaborate with the
Health and Safety team to develop and
implement the Occupational Health and
Safety Program.
The HR team should collaborate with the
Community Relations team to implement
the grievance mechanism.
-Monitoring of company and
contractor compliance with the
company policies and local
laws;
-Numbers of Labour related
grievances filed each quarter;
types of issues raised and by
whom; and percent resolved by
type;
-Occupational Health and
Safety monitoring against
indicators to be established
through the development of the
OHS Program;
-Quarterly audits of working
conditions and to verify there
are no cases of child Labour or
forced Labour at the Project
site.
If necessary, training on
national employment and
Labour laws.
Health and safety training to
promote safe working
conditions.
Worker policies and
procedures should be
established prior to the
beginning of the
construction phase. The
policies should reflect
company and national
standards and should be
updated throughout the
Project lifecycle.
Annexure 25-P1-
PDMSA – Internal
Regulation- Approved
by Ministry of Labour
Government of
Mozambique
Annexure 25-P4-
Worker Health & Safety
Management Plan
Annexure14- HSE
clause –EPC Contractor
Social: Accidents and incidents
may occur within the Project site
and/or may affect neighbouring
communities.
o Establish Emergency
Preparedness and Response Plan
to cover the risks and hazards that
may result in emergency
situations and the required
response to these emergencies.
o Develop an Occupational Health
and Safety Program to minimize
and manage health and safety
risks to workers on site.
o Establish a Community Health
and Safety Plan to outline
additional measures related
specifically to dealing with
emergencies or incidents that
affect local communities.
o Identify and train personnel to
lead emergency situations and
ensure provision of appropriate
emergency preparedness and
response equipment and supplies.
o Share relevant information with
and train local communities and
government authorities as
appropriate (including involving
them in simulations of emergency
situations which may affect
them), to ensure their capacity to
assist or cooperate with response
efforts as needed.
The PDMSA Health and Safety (H&S)
team is responsible for identifying and
establishing roles for emergency response
participants. The H&S team should keep a
constantly updated log of emergency
situations that occur and update the Plan to
reflect the current Project lifecycle.
Development and implementation of the
Community Health and Safety Plan should
be coordinated among the H&S Team, the
Environment Team and the Project’s CR
team.
Quarterly audits to
verify that all active workers
and contractors have received
Emergency Preparedness and
Response training and know the
protocols during an emergency
situation;
Number of trainings and
simulations offered for
communities and local
government staff and number of
participants
completing each training;
OHS and Community Health
and Safety monitoring
indicators (to be developed as
part of OHS and CHS
programs);
Ongoing maintenance
/ auditing of emergency
response. equipment
Establishment and training
of Emergency Coordinators
and teams on emergency
response protocols
Training and simulations
with local communities and
local authorities on
emergency response
procedures and measures
The Emergency
Preparedness and Response
Plan and Community Health
and
Safety Plan should be
established in consultation
with local communities and
government authorities
during the ESIA progress.
The Plan should be in place
at the inception of
construction activities and
updated throughout the
Project lifecycle.
Emergency
Preparedness and
Response Plan((To be
developed and
submitted for lender
review- Prior to Labour
Mobilization)
Annexure 25-P4-
Worker Health & Safety
Plan
PDMSA- Occupational
Health & Safety policy
Annexure14- HSE
clause –EPC Contractor
Waste: Hazardous materials,
including petroleum products,
will be used, stored and handled
o Establish a Hazardous Materials
Management Plan outlining
requirements and procedures to
The PDMSA Environment and Health and
Safety teams are responsible for
-Quarterly audits against
indicators to be established in
the Hazardous Materials
Training for workers and
contractors who may handle
or come into contact with
Establish plan prior to the
start of construction;
Annexure 25 –P3-
Construction
by the Project. Without proper
controls, hazardous materials
can impact the safety of the
workforce and surrounding
communities through spills,
accidental releases and/or
explosions.
safely manage, store and utilize
hazardous material, including
agricultural and pest-control
chemicals and inputs. The Plan
should comply with specific
requirements as outlined in IFC’s
HSE Guidelines.
o Establish transportation
guidelines for the transport and
storage of hazardous material,
including transporting material on
routes and during times to
minimize public exposure.
o Ensure that all hazardous
materials are clearly identifiable
and labelled.
o Coordinate the Plan with the
Emergency Preparedness and
Response Plan and the
Community Health and Safety
Plan, particular with respect to
disclosure of hazardous materials
related risks and disclosure /
training on emergency response
measures in the event of an
accidental release, spill or
explosion.
establishing training, signage and storage
procedures for hazardous material.
The Community Relations team should
disclose and consult with local communities
and authorities on what hazardous materials
are being used in Project area, the risks
associated with the materials and
emergency response measures in the event
of a spill.
Management Plan, to verify that
all hazardous materials are
being properly handled and
stored;
-Records of all workers and
contractors that have received
the hazardous materials training
plus ongoing refresher courses;
-Root cause analyses and
corrective actions taken in the
event of an incident and
ongoing environmental
monitoring as needed following
a release of hazardous materials
into the environment
hazardous materials and
emergency actions to follow
in the event of spillage,
release or accidents. The
training may occur in
coordination with
Emergency Preparedness
and Response training.
implement throughout the
project lifecycle
Environmental
Management Plan
PDMSA-
Environmental Policy
Transportation: The Project
requires the transportation of
people, supplies, products and
wastes (including hazardous
materials) to, from and within
the Project area. Transportation
will make use of public road
o Conduct a Traffic Risk
Assessment, including a
description of the scope of
Project-related traffic and
identification of all areas sensitive
The Traffic Risk Assessment should be
carried out by competent professionals with
experience in traffic issues. The CR team
should be engaged during the assessment
process, to conduct consultations with local
authorities and other key stakeholders who
can provide local perspectives on traffic-
Quarterly audits to check that
Project drivers meet necessary
licensing requirements and are
aware of the traffic regulations
If necessary, driver training
on national traffic
regulations should be held
on an annual basis.
If necessary, driver training
on proper vehicle
The Transportation Health
and Safety Plan should be in
place prior to the
commencement of
transportation activities and
should be reviewed and
updated annually.
Traffic Risk Assessment
& Safety Plan (to be
developed and
submitted for lender
review before start of
construction)
infrastructure, which passes
through various communities.
Traffic-related accidents may in
turn pose a risk to the health,
safety and quality of life of those
communities.
to traffic risks and the current
state of road repair.
o Based on the Traffic Risk
Assessment, develop and
implement a Road Maintenance
and Monitoring Plan to be
implemented in coordination with
local authorities to ensure that any
deterioration in the quality of the
Road caused by the Project is
identified and immediately
repaired
o Develop a Transportation Health
and Safety Plan establishing the
policies and procedures to
manage driver conduct, training
and health and safety measures.
The Plan should include
requirements and management
measures to ensure Project-
related transit is conducted safety,
including speed limits, vehicle
maintenance and requirements
related to night time driving.
o A roster of drivers should be
available and maximum shift
lengths established, to prevent
driver fatigue.
related risks and necessary management
approaches.
The Road Maintenance and Monitoring
Plan should be developed and implemented
jointly with local transit authorities.
The PDMSA Health and Safety and
Logistics teams are responsible for
developing and implementing the
Transportation Health and Safety Plan,
including ensuring proper licensing of
drivers and full knowledge of national
traffic regulations.
Semi-annual audits to check the
maintenance of Project and
contractor vehicles.
Road maintenance monitoring,
as per parameters to be
established within the Road
Maintenance and Monitoring
Plan.
maintenance should be held
to help ensure vehicles are
in proper working condition.
PDMSA- Occupational
Health & Safety Policy
Annexure14- HSE
clause –EPC Contractor
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