LIBERIA ELECTRICITY CORPORATION AND RURAL AND RRENEWABLE ENERGY AGENCY Liberia Electricity Sector Strengthening and Access Project – Phase 2 (LESSAP-2) P180498 ENVIRONMENT AND SOCIAL COMMITMENT PLAN (ESCP) 15 May 2024 Draft ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Liberia (the Borrower) will implement the Liberia Electricity Sector Strengthening and Access Project (the Project), with the involvement of the following ministries/agencies/units: The Ministry of Finance and Development Planning (MFDP) and Ministry of Mines and Energy (MME), working through the Liberia Electricity Corporation (LEC) and the Rural and Renewable Energy Agency (RREA), the implementing agencies in consultation with other relevant line ministries and agencies. The International Development Association acting through the World Bank (the Bank) has agreed to provide financing for the Project. 2. The Borrower will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. The GoL will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Impact Assessment (ESIA), Environmental and Social Management Plans (ESMP), Resettlement Policy Framework (RPF), Resettlement Action Plan (RAP), Labor Management Procedures (LMP), and Stakeholder Engagement Plan (SEP), and the timelines specified in those E&S documents. 4. The Borrower is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry, agency or unit referenced above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Bank by the Borrower as required by the ESCP and the conditions of the legal agreement, and the Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank and the Borrower, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the Borrower will agree to the changes with the Bank and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Bank and the Borrower. The Borrower will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance results in changes to the risks and impacts during Project implementation, the Borrower shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A MONITORING: The work of the consultant shall be supervised by the Project Throughout project LEC and RREA Implementation Unit’s (PIU) Environmental and Social Management Unit implementation (ESMU). The PIU shall be responsible for monitoring the performance of Contractor(s) in relation to contracted workers. Impact and compliance monitoring shall be conducted during the construction and operation phases of the proposed project. Monitoring shall be conducted to verify the predicted impacts, examine the implementation and effectiveness of mitigation measures, respond to unanticipated environmental impacts, and improve environmental controls. Monitoring shall be conducted by trained individuals following monitoring and recordkeeping procedures and using properly calibrated and maintained equipment. Civil works supervision engineers shall monitor compliance to the CESMP by the civil work contractors during their regular site supervision. During implementation of the project components, the contractor shall be supervised by the ESMU with the support of the Environmental Consultant, when required. The contractor shall ensure that it is correctly implementing the CESMP and is meeting all conditions of the Environmental Permit(s) issued by the EPA for the project component activities. Use an ESMP checklist shall be used to monitor construction activities to Every quarter ensure compliance. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY The contractor shall submit to the Bank an environmental and social compliance monitoring report for review and clearance. Monitoring data shall be analyzed and reviewed at regular intervals and compared with the operating standards so that any necessary corrective actions can be taken. Monitoring activities shall be undertaken during general construction and/or rehabilitation activities and include: • Environmental - Air quality; noise levels; waste disposal; end of life batteries and others; water quality; soil disturbances; tree clearing / trimming; traffic disturbance; and occupational health and safety. • Social – Job created by the project; and cultural sites. In addition to the quarterly E&S compliance monitor reporting, the ESMP provisions for reporting implementation progress shall be monitored and reported in the project’s semi-annual progress reports and periodic reports. The overall safeguards implementation process shall be supervised and monitored, and progress reports on the application of safeguards during the planning, design, and construction phases of the Project shall be prepared. B REGULAR REPORTING: The Borrower shall develop the reporting requirements and procedures to Within one month of notice to LEC and RREA ensure compliance of the contractor(s). proceed 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY The Borrower shall prepare and submit to the Bank regular monitoring Quarterly throughout the project LEC and RREA reports on the environmental, social, health and safety (ESHS) performance implementation period of the Project, including, but not limited to, stakeholder engagement activities and review of GRM records. The regular reporting will also cover progress on the implementation of the ESCP C INCIDENTS AND ACCIDENTS: The Project will promptly notify the Bank of any incident or accident related Notify the Bank within 48 hours LEC and RREA, to, or having an impact on, the Project, which has, or is likely to have, a after learning of the incident or Contractor(s) significant adverse effect on the environment, the affected communities, accident. the public or workers. This will include workplace accidents, incidence of SEA/SH, Protection of Woman and Child Adolescent Health and well-being, maternal mortality and the notification of teenage pregnancy, labor related, work & vehicle related. This report will be submitted to the World Bank and the Ministry of Mines and Energy. Subsequently, if requested by the Bank, the Borrower shall prepare a A subsequent detailed report LEC and RREA report on the incident or accident and propose any measures to address it would be provided within a and prevent its recurrence. timeframe acceptable to the Bank/Association. D CONTRACTORS’ MONTHLY REPORTS: Contractors’ monitoring reports to the Project Implementation Unit (PIU) Monthly throughout the project LEC and RREA, shall cover ESHS aspects. implementation period Contractor(s) monthly civil/electrical work progress reports. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY The status of ESMP implementation shall be incorporated regularly in the Monthly throughout the project LEC and RREA PIU’s monthly report. implementation period Per the LMP, a regular employment report (e.g., Names of staff, category, Monthly or more frequently as Contractor(s) ages, gender, hours work and wages paid), incident report including defined in ESMPs. grievances shall be submitted by contractors on a monthly basis or at shorter intervals as defined by specific ESMPs. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE: The LEC and RREA will utilize their existing PIUs and E&S specialists for the Throughout the Project LEC and RREA grid and off-grid components respectively for LESSAP-2 (Note: LEC currently has 7 E&S specialists in the LEC PIU that serve all WB funded projects. An 8th specialist (social/gender) is currently being recruited; RREA has 5 E&S specialists)1. These E&S specialists have gained some experience working on the ongoing Bank financed projects, including LESSAP-1. LEC has additional senior social safeguard / safety specialists to oversee the rehabilitation / installation works in electrified communities. 1 Responsibilities of an OHS Specialist are shared within the PIU, specifically by the Environmental and Social Safeguard Unit. The current environmental specialist has obtained a NEBOSH certificate in OHS and participated in several OHS and ESRM training facilitated by the World bank. Hence, has acquired the relevant skills and competency to undertake OHS duties on LESSAP. The environmental specialist at LEC also conducts incident investigation and reporting, health and safety induction for workers, reviewing contractors’ risk management plans, Workers’ GRM etc. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS: An Environmental and Social Management Framework (ESMF), including Implement the ESMF along with LEC and RREA an Environmental and Social Management Plan (ESMP) , and a its ESMP framework and the RPF Resettlement Policy Framework (RPF), were prepared under LESSAP-1. The throughout Project ESMF sets out the principles, rules, guidelines and procedures that LEC and implementation. RREA will follow when assessing the environmental and social risks and impacts of subprojects’ activities. The RPF has set out the principle, policies, rules, guidelines and procedures to prepare Abbreviated Resettlement Action Plans (ARAP) / Resettlement Action Plans (RAP) should land acquisition, restriction on land use and/or involuntary resettlement is required by the Project. The Borrower shallwill update, disclose and adopt the ESMF and RPF prepared under Phase I for Phase II by effectiveness, which will then guide the preparation By effectiveness of subsequent E&S screening and ESMPs according to ESF, GIIP, and WB EHS Guidelines. The Borrower is required to update and adopt the SEP prepared under Phase I, . By Appraisal The Existing ESCP for Phase I will be updated for Phase II to address the environmental and social obligations of the borrower as by the relevant ESSs and national regulations. Screening to identify the nature and magnitude of LESSAP project Prior to project implementation LEC and RREA components’ potential environmental and social impacts and determine the category to which such projects belong (A, B, or C) was completed under LESSAP-1. No ESIA has been proposed for LESSAP-2. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY PIU Procurement Department shall select and hire a consultant from a list Prior to project implementation LEC and RREA of EPA certified Environmental Evaluators to conduct relevant environmental and social impact studies from an independent impact assessment viewpoint, when required. An environmental audit shall be conducted in cases where an existing site Throughout Project LEC and RREA is being rehabilitated and in cases where PCBs are involved. implementation if and when required Environmental permits identified in the ESMF shall be obtained for Prior to project implementation LEC and RREA construction works. 1.3 MANAGEMENT TOOLS AND INSTRUMENTS: The ESMF, LMP, SEP and RPF have been prepared thereby satisfying the Prepared, cleared by association, LEC and RREA requirements of the Environmental Protection Management Law (EPML) disclosed and fully implemented of Liberia. prior to moving to the site for No ARAPs / RAPs were required for LESSAP-1. The requirement for clearance for starting civil work ARAPs/RAPs has not been identified for LESSAP-2, if requires, will be prepared in the event that land acquisition, restriction of land use or involuntary resettlement is identified for LESSAP-2. However, the SEP prepared for LESSAP Phase I, shall be updated disclosed and adopted for Phase II by appraisal. While the ESMF, LMP and RPF shall be updated, disclosed and adopted by By appraisal effectiveness. Preparation of Environment, Health and Safety (EHS) Plan and E-waste By effectiveness management plan as stand-alone documents or part of the ESMP both for construction and operation; 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY o ESMP and LMP provisions to be included in the Bidding documents and contracts. 1.4 MANAGEMENT OF CONTRACTORS: Prior to the preparation of LEC and RREA The Borrower shall incorporate the relevant E&S aspects identified in the procurement documents ESMF and the LMP into the ESHS specifications of the procurement documents for civil works. Measures related to hazardous waste and OHS management shall be identified in the procurement documents. Thereafter contractors shall comply with the ESHS specifications of their Throughout Project LEC and RREA respective contracts. implementation. 1.5 PERMIT, CONSENTS AND AUTHORIZATIONS: The Borrower shall seek and obtain the necessary approvals, permits and Prior to initiating activities that LEC and RREA authorizations from the Environmental Protection Agency (EPA) and other require permits, consents and relevant national authorities as applicable. authorizations The Project shall comply or cause to comply, as appropriate, with the conditions established by these permits, consents and authorizations throughout Project implementation. 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY 1.6 EXCLUSIONS: The following type of activities are ineligible for financing under the During the ESMF process LEC and RREA Project: • Activities that may cause long term, permanent and/or irreversible adverse impacts; • Activities that may have significant adverse social impacts; • Activities that harm the rights of vulnerable people; • Activities that may have adverse impacts on cultural heritage; and • All the other excluded activities set out in the ESMF of the Project. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES (LMP): The Project shall be carried out in accordance with the applicable Throughout Project LEC and RREA, requirements of ESS2, in a manner acceptable to the Bank, including implementation Contractor(s) through, inter alia, implementing adequate occupational health and safety measures (including emergency preparedness and response measures), setting out grievance arrangements for workers, and incorporating labor requirements into the ESHS specifications of the procurement documents and contracts with contractors and supervising firms specifically on labor management, worker accommodations, grievance procedures and provision to avoid any SEA/SH incidences. The LMP has been prepared and shall be updated disclosed, adopted, and By effectiveness LEC and RREA implemented consistent with ESS 2. The LMP shall be updated and rporated into the [ESMP]. 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY Contracts with selected contractors shall include provisions related to labor Prior to project implementation LEC and RREA, and occupational health and safety, as provided in the World Bank 2018 Contractor(s) Standard Procurement Documents. Overall project coordination, including implementation of the LMP, shall Throughout Project LEC and RREA remain the responsibility of LEC and RREA. implementation Both PCMU/PIUs shall have an Environmental and Social Management Unit Throughout Project LEC and RREA (ESMU) in charge of overseeing the implementation of the LMP and other implementation Safeguards related subjects, with E&S specialists tasked with coordinating all activities under the LMP at the PCMU/PIUs level. For project activities involving renovation/refurbishment and minor civil Daily Contractor(s) works, the contractor(s) shall oversee labor and safety performance on a regular basis (daily) on behalf of the Employer. The PIU safeguard team shall closely supervise the Contractor Recruitment Throughout Project LEC and RREA Plan and ensure recruitment procedures are transparent, public and non- implementation discriminatory, and open with respect to ethnicity, religion, sexuality, disability or gender. Specific measures to be implemented by the contractor(s) and monitored Throughout Project Contractor(s), LEC and by the PCMU/PIU safeguard team shall include: implementation RREA • Provide all information and documentation at the beginning of the working relationship and when any material changes to the terms or conditions of employment occur. • Where applicable, provide project workers with written notice of termination of employment and details of severance payments in a timely manner. 10 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY • Pay project workers on a regular basis as required by national law and labor management with a principle of “equal pay for equal work�. • Provide all project workers with adequate periods of rest per week, annual holiday and sick leave, as required by national law. • Base employment of project workers on the principle of equal opportunity and fair treatment, with no discrimination with respect to any aspects of the employment relationship, such as recruitment and hiring, compensation (including wages and benefits), working conditions and terms of employment, access to training, job assignment, promotion, termination of employment or retirement, or disciplinary practices. • Safeguard the interests of women and girls, including gender parity at the workspace, provision of appropriate sanitation facilities at workplace and appropriate PPEs for women. • Encourage minimizing risks related to labor influx by utilizing community labor or local contractors wherever possible. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: The Project shall develop and operate a separate grievance redress sEtablish before start of the LEC and RREA, mechanism [GRM], as described in the Labor Management Plan (LMP) and work, Maintained and operated Contractor(s) consistent with ESS2, for project workers’ contracts, with specific GRM for throughout project contractor staff in line with the LMP, SEP and ESMF to address worker implementation. grievances and shall be maintained and operated throughout project implementation. The Contractor shall inform workers, and sub-contractor(s), and display Prior to start of the work Contractor(s) publicly at each work-site the information about the existing project GRM. 11 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY A GRM committee responsible for investigating and resolving labor related Prior to implementation LEC and RREA, complaints shall be set up at the LEC/RREA. The committee shall comprise Contractor(s) five (5) persons and the meeting of any three (3) persons shall constitute a quorum. The GRM committee shall be headed by the PIU/PCMU coordinator and the Prior to implementation LEC and RREA, secretary to the committee shall be the social safeguard staff recruited at Contractor(s) the PIU/PCMU. 2.3 OCCUPATIONAL HEALTH AND SAFETY MEASURES: Contractor(s), in accordance with contract specific Labor Management Throughout project LEC and RREA, Plans, shall have primary responsibility for workplace health and safety, implementation Contractor(s) and shall be required to respect guidelines provided in the LMP, implementation of which will be supervised by Safeguards Specialists at LEC and RREA. Contractor(s) shall be required to hire a qualified and experienced OHS Prior to implementation Contractor(s) Specialist and prepare detailed OHS plan for the management of labor/OHS issues. Contractor(s) shall develop a TOR for recruiting an OHS Specialist, subject Prior to implementation Contractor(s), LEC and to review and approval by the safeguard team of LEC/RREA. RREA 12 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY Contractor(s) shall prepare and implement their respective site specific At the deployment of workers on Contractor(s), LEC and OHS plans, as necessary. The OHS measures shall be followed throughout the project site and prior to RREA project implementation. They shall address: (a) identification of potential commencement of civil work and hazards to project workers, particularly those that may be life-threatening; implemented throughout the (b) provision of preventive and protective measures, including project life modification, substitution, or elimination of hazardous conditions or substances, and use of personal protective equipment (PPE); (c) training of project workers and maintenance of training records; (d) documentation and reporting of occupational accidents, diseases and incidents; (e) emergency prevention and preparedness and response arrangements; and (f) remedies for adverse impacts such as occupational injuries, deaths, disability and disease. The project contractor shall conduct occupational health and safety At the deployment of workers on Contractor(s), LEC and awareness for workers in the following areas: the project site and prior to RREA commencement of civil work and • Occupational health and safety; implemented throughout the • Emergency preparedness and response; project life • Community health and safety; • E&S risk management; • Labor management procedures; and • Gender-based violence and SEA/SH The Project shall ensure that contractors, subcontractors and their workers At the deployment of workers on LEC and RREA, are trained and are aware of risks and avoid and mitigate impacts on local the project site and prior to Contractor(s) communities. LEC/RREA shall develop a training manual indicating staff commencement of civil work and and the training schedule to address risks related, but not necessarily implemented throughout the limited, to: project life • Slips and falls • Falls from height 13 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY • Contact with moving parts of machines and tools • Contact with electrical tools and wires (electrocution) • Inadequate wiring and overloaded circuits • Exposure to hazardous substances • Overexertion • Moving vehicles and equipment and falling objects • Exposure to high level of noise • Heat exhaustion • Exposure to dust and damaged insulation • Exposures to metal fumes and to ultraviolet (UV) radiation • Exposure to hand-arm vibration (HAV) or whole-body vibration (WBV) • GBV and SEA/SH Measures adopted by the Project for addressing occupational health and At the deployment of workers on LEC and RREA safety issues shall apply to civil servants assigned to serve in the PCMU/PIU the project site and prior to of the Project. commencement of civil work and implemented throughout the project life ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 14 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY 3.1 WASTE MANAGEMENT PLAN: Handling and disposal of hazardous waste (lithium batteries, solar panels To be included in the ESMP to be LEC and RREA, and transformer oils) and e-wastes (meters) are potential ESHS risks prepared prior to project Contractor(s) associated with LESSAP-2. A waste management plan shall be developed, implementation and consistent with ESS3, within the CESMP for review and approval by the implemented throughout project ESMU/PIU. It will cover solid wastes, liquid wastes, gaseous wastes and implementation. hazardous wastes, including safe handling and disposal of hazardous wastes such as lithium batteries and solar panels and e-wastes that will be generated under the project. To be included in the ESMP to be LEC and RREA, There are limitations with the disposal of hazardous waste in Liberia as no prepared prior to project Contractor(s) hazardous waste disposal site is available. The Liberian Environmental implementation and Protection Agency (EPA) has a list of waste service providers responsible implemented throughout project for disposal of hazardous waste through the process of recycling. For implementation. disposal purposes, the waste service providers shall be contracted. The manufacturers of the solar panels and batteries shall be contacted for repair or replacement, where possible. The manufacturers shall be contracted to conduct basic operation and maintenance training for the safeguard team of LEC and RREA, EPA and MOH technicians. Furthermore, the environmental safeguard team shall conduct routine Throughout project LEC and RREA, monitoring during construction and operation phases to ensure safe implementation Contractor(s) handling and disposal of hazardous end e-waste. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: To be included in the ESMP to be LEC and RREA, Most of the wastes from the project activities will be generated during the prepared prior to project Contractor(s) civil works. They will be mainly construction related wastes that can be implementation and easily handled and managed. implemented throughout project implementation. 15 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY The ESMP prepared for the project shall be implemented and a To be included in the ESMP to be LEC and RREA, Construction Environmental and Social Management Plan (CESMP) prepared prior to project Contractor(s) outlining specific mitigation measures for effective implementation and management/monitoring of E&S risks associated with LESSAP, including implemented throughout project procedures for disposal of construction waste materials, shall be prepared implementation. and implemented. All agreed measures described in the CESMP shall be included as appropriate. A separate budget line for smooth implementation of the ESMP shall be prepared. The ESMP shall be shared and communicated with subcontractor(s) to ensure the ESMP is implemented during project construction works. The ESMP shall include sub-plans as follows: • Air quality • Noise • Waste management • PCB waste • Hazardous waste • Damage to private property • Surface water • Soil and groundwater • Flora and fauna; erosion • Land clearing • Dust and noise during construction • Traffic • Worker health and safety • Community health and safety • Protecting workers and local communities from COVID-19 16 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY • Gender and socio-economic • Physical cultural resources (Chance Find Procedure) ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: To be finalized and approved Contractor(s) The project contractor shall develop and implement an Occupational prior to commencement of civil Health and Safety Management Plan as well as Traffic and Road Safety works. Management Plan to mitigate adverse project impacts on beneficiary communities as well as safeguard project affected communities from traffic and road safety risks, diseases and hazardous materials associated with project implementation and operation. The contractor’s environment, health and safety plan shall include a traffic management plan as required by the ESMP. The contractor shall coordinate with National traffic authorities (e.g., the Liberia National Police) to guide the implementation of the traffic management plan. 4.2 COMMUNITY HEALTH AND SAFETY: The contractor shall develop and implement measures and actions to Maintain throughout Project Contractor(s) assess and manage specific risks and impacts to the community arising implementation. from project activities, including in relation to project workers and any risks of labor influx. Particular focus shall be on the workers’ work place behavior with prohibition on disturbance to the local community. Implement key safety and health protocols for stakeholder engagement. LEC and RREA 4.3 SEA AND SH RISKS: 17 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY A GBV risk assessment shall be conducted and measures and actions Update GBV action plan of Phase developed and implemented to manage the risks of SEA/SH that may arise I prior to effectiveness, adopt during project implementation. and implement prior to start of the project implementation . ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK: Minimum land acquisition was expected under LESSAP-1, but because Update RPF and disclsoe prior to LEC and RREA/GOL exact project component locations was not known at that time, a draft effectivness and implement Resettlement Policy Framework (RPF) was prepared for the Project, throughout the project life. consistent with ESS5, to guide assessment of the impact of planned project activities on assets and livelihoods. 5.2 RESETTLEMENT ACTION PLANS: Following preparation of the RPF for LESSAP-1, it was subsequently determined that no land acquisition was required for LESSAP-1 and, therefore, no Resettlement Action Plan (RAP) was needed. In the event of any need of land acquisition, restrictions on land use and Prior to site handover to the LEC and RREA/GOL involuntary resettlement under LESSAP-2, site specific Resettlement Action contractor(s) and the Plans will be prepared, and implemented, and a compensation and commencement of any activities resettlement assistance completion report shall be prepared and in project area(s) that requires submitted to the Bank to obtain NOC prior to start of the work. the land 18 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY LEC and RREA/GOL In the event of involuntary resettlement becoming necessary, compliance Prior to site handover to the LEC and RREA/GOL with ESS5 and the laws of Liberia and regulations of relevant agencies and contractor institutions will be necessary to mitigate any adverse impacts. In such cases, a compensation and resettlement completion report shall Two weeks after compensation LEC and RREA/GOL be prepared for each subproject. payment completion and three months prior to site handover to the contractor for each site Site(s) shall be handed over to the contractor. Three months after completion LEC and RREA/GOL of compensation payments in the entire subcomponent impact corridor 5.3 GRIEVANCE REDRESS MECHANISM: In the event that any resettlement actions are required, the grievance redress mechanism (GRM) developed to address resettlement related Include when documents are LEC and RREA/GOL complaints shall be described in RPF, RAP and SEP documents prepared for drafted and established after LESSAP-2. baseline survey conducted ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: ESS 6 is not considered relevant to the project at this time as none of the project components will occur in natural habitats or in areas with biodiversity. The project components will be developed within urban areas or small towns. Maintain correct spacing between energized components, and evaluate During MV&D construction Contractor(s) the need for bird deterrents or diverters, insulated jumper loops, and 19 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY elevated perches to protect avian fauna to mitigate the risk of bird collisions, especially for large terrestrial birds that will be at increased risk of collision with the earth wire. Ensure adequate selection of the location of the district offices or routes During MV&D construction Contractor(s) for the distribution lines to reduce impacts on biodiversity. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL 7.1 This standard is not considered relevant for LESSAP-2. The preliminary Not Applicable assessment suggests that there are no distinct social and cultural groups in the project area who exhibit characteristics akin to the criteria for indigenous or traditionally under-served communities as defined in the ESS7. ESS 8: CULTURAL HERITAGE 8.1 This standard is considered relevant even though the project activities may Throughout project LEC and RREA, not have an impact on tangible and intangible cultural heritage. In the implementation. Contractors unlikely event of construction or the movement of earth in connection with any project activities that have not yet been anticipated, a chance find procedure has been prepared and integrated into the ESMF and will be implemented for the Project. ESS 9: FINANCIAL INTERMEDIARIES Not relevant to LESSAP-2 20 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION: Updated SEP to be disclosed 10 LEC and RREA A Stakeholder Engagement Plan (SEP) was prepared for LESSAP-1, and has days prior to DM/Appraisal been updated for LESSAP-2. It shall be disclosed, consulted, adopted, and implemented consistent with ESS10 including measures to, inter alia, provide stakeholders with timely, relevant, understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. Key activities shall include, but not necessarily be limited to, the By Appraisal following: • Updating and consultation and disclosure of the existing Environmental and Social Commitment Plan (ESCP) – Before Appraisal; • Updating and consultation and disclosure of an existing Stakeholder Engagement Plan (SEP), including draft grievance redress mechanism (GRM) - Before Appraisal; • Updating and, consultation and disclosure of existing Environmental and Social Framework (ESMF), Resettlement Policy Framework (RPF) and Labor Management Procedures (LMP) by effectiveness. By effectiveness • Possible issues to be addressed in the Borrower Environmental and Social Commitment Plan (ESCP): • Institutional arrangements for the management of ESS standards; To be implemented throughout • Finalize the update of RPF, LMP, and SEP in a timely manner; project implementation 21 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY • Updated Environmental and Social Management Plan (ESMP) for construction and operation phases for Components 1, 2, and • Implementation and supervision of SEA/SH Action Plan; • Development and implementation of institutional environmental and social capacity strengthening plan; • Preparation of Environment, Health and Safety (EHS) Plan and E-waste management plan as stand-alone documents or part of the ESMP both for construction and operation; • ESMP and LMP provisions to be included in the Bidding documents and contracts. • Conduct public consultation and public awareness programs. LEC and RREA LEC and RREA • Publish a “notice of intent� that states the information that may be LEC and RREA necessary to allow the stakeholders or any interested party to identify their interest in the proposed project or activity following submission of any application for an environmental impact assessment permit. Information to include: the nature of the project, its related activities, its timeframe and its site of operation and the area that may be impacted. LEC and RREA LEC and RREA LEC and RREA By Appraisal LEC and RREA / WB 22 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY • Ensure meaningful consultations with various stakeholders LEC and RREA (including project affected communities, women and youth groups, NGOs, line ministries, community-based groups and other vulnerable and disadvantaged members of the communities) throughout the project life cycle. • Provide stakeholders with accessible and inclusive GRM to raise LEC and RREA issues and grievances, that will allow LEC to receive, respond to, facilitate resolution of concerns and manage grievances. • Ensure that all stakeholder consultations are accessible and LEC and RREA inclusive (in format and location), and that these consultations will be appropriate for the local context. • Provide stakeholders with timely, relevant and understandable LEC and RREA information in a culturally appropriate format. • Undertake consultations with the following stakeholder groups: LEC and RREA Government and regulatory relations; Non-governmental organizations; Local stakeholders; and Disadvantaged and vulnerable groups. • Publicly disclose any ESIA prepared in accordance with EPA and LEC and RREA World Bank requirements. • Disclose all safeguards documents in public locations within Liberia. LEC and RREA Make simplified summaries available. Documents to be made 23 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY available in English in compliance with the World Bank’s Public Consultation and Disclosure Policy. • Use a variety of communication methods to reach the majority of LEC and RREA stakeholders. 10.2 PROJECT GRIEVANCE REDRESS MECHANISM (GRM): GRM to be in place and LEC and RREA functioning prior to project A grievance redress mechanism (GRM) has been developed for LESSAP, implementation and thereafter that is designed to resolve complaints and grievances in a timely, maintained and operated effective, and efficient manner, and will build, strengthen and upgrade throughout Project the existing GRMs already established and being managed by LEC and implementation. RREA for ongoing World Bank financed projects LACEEP and AF (P133445), and LIRENAP(P149683), in a manner consistent with ESS10. Key activities shall include, but not necessarily be limited to, the following: • Handle grievances at the local community and project level LEC and RREA (PCMU/PIU) by Grievance Redress Committees (GRCs) comprised of representatives of project affected and interested persons including local community leaders established through PCMU/PIUs at LEC/RREA, including via a dedicated hotline which will be established. • Where grievances cannot be resolved at the local level, provide the LEC and RREA aggrieved person with the option to refer the matter to the PCMU/PIU at LEC and RREA for redress. • If the complainant is still dissatisfied with decision reached at the LEC and RREA PCMU/PIU, he/she may have an option to seek judicial remedy. 24 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY • Contractor(s) shall be required to identify focal points and Contractor(s) communication channels (for example, WhatsApp, SMS and email) within the company to address workers’ concerns on an ongoing basis, and ensure that such channels are adequately resourced (for example, 24-hour staffing of the emergency response call line). • The grievance mechanism shall be equipped to receive, register, LEC and RREA and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 LEC/RREA shall develop a training manual identifying staff and the training Prepare a training manual LEC and RREA schedule for E&S staff of LEC and RREA as they are relatively new to within 30 days of effectiveness ESF/ESSs notwithstanding exposure to ESF/ESSs in LESSAP-1. of LESSAP-2 CS2 Staff involved in E&S will regularly attend training to discuss and address Ongoing throughout life of LEC and RREA emerging issues and challenges in E&S implementation. project CS3 The Project will implement training for project workers designed to Prior to commencing work or LEC and RREA heighten awareness of risks and to mitigate impacts on local communities. employment and regular The project will ensure that contractors, subcontractors and their workers refresher training throughout project implementation. are trained and are aware of risks and requirements to mitigate impacts on local communities, including receiving training on occupational health and safety and emergency prevention and preparedness and response arrangements to emergency situations. CS4 The Project will support the following basic trainings: The relevant trainings or LEC and RREA capacity building interventions 25 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Liberia Electricity Sector Strengthening and Access Project – Phase 2 MATERIAL MEASURES AND TIMEFRAME RESPONSIBLE ENTITY • Introduction & understanding of ESS1-10; for implementing agencies will be financed by Project • Basics training on preparation and implementation of RAP; Component 3 • Requirements for implementing and updating SEP, on an as required basis; • E&S requirements integration in the bidding document and procurement process; • Implementing and supervising the relevant ESSs under the Project CS5 Open training sessions for individuals from the EPA, MOH and other Within 3 months of notice to LEC and RREA concerned ministries and governmental authorities to strengthen proceed institutional capacity and environmental and social awareness. Conduct post-training appraisals of training sessions to improve the Following delivery of each LEC and RREA training program training module 26 | P a g e