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ESMF For Somali Electricity Access Project Somaliland 1

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Public Disclosure Authorized

GOVERNMENT OF SOMALILAND
Public Disclosure Authorized

MINISTRY OF ENERGY AND MINERALS

SOMALI ELECTRICITY ACCESS PROJECT (SEAP)


Public Disclosure Authorized

ENVIRONMENTAL AND SOCIAL MANAGEMENT


FRAMEWORK (ESMF)
Public Disclosure Authorized

FINAL

© September 2018
Somali Electricity Access Project (SEAP) 2018

TABLE OF CONTENTS
TABLE OF CONTENTS .................................................................................................................. I
LIST OF TABLES .......................................................................................................................... III
ACRONYMS AND ABBREVIATIONS ......................................................................................... IV
EXECUTIVE SUMMARY ...............................................................................................................1
1 INTRODUCTION AND PROJECT CONTEXT .......................................................................8
1.1 PROJECT CONTEXT ........................................................................................................................ 8
1.2 PROJECT DESCRIPTION .................................................................................................................. 9
1.3 PROJECT DEVELOPMENT OBJECTIVES .......................................................................................... 9
1.4 PROJECT BENEFICIARIES ............................................................................................................... 9
1.5 PROJECT COMPONENTS ............................................................................................................... 10
1.5.1 Component 1: Electrification of households and small businesses through standalone solar
home systems....................................................................................................................................... 10
1.5.2 Component 2: Analytical work for enabling electrification through solar powered/hybrid
mini-grids ............................................................................................................................................ 13
1.5.3 Component 3: Technical assistance, capacity building and project management ............. 14
1.6 PROJECTS EXCLUDED FROM FINANCING ..................................................................................... 14
2 SCOPE AND METHODOLOGY OF THE ESMF .................................................................. 15
2.1 ESMF JUSTIFICATION ................................................................................................................. 15
2.2 ESMF PRINCIPLE ........................................................................................................................ 15
2.3 METHODOLOGY .......................................................................................................................... 15
3 POLICY, LEGISLATIVE AND INSTITUTIONAL FRAMEWORKS ................................... 17
3.1 SOMALILAND LAWS AND LEGISLATIONS ..................................................................................... 17
3.2 WORLD BANK SAFEGUARDS OPERATIONAL POLICIES ............................................................... 19
3.3 WORLD BANK GROUP EHS GUIDELINES .................................................................................... 20
4 PROJECT BIOPHYSICAL AND SOCIOECONOMIC SETTING ......................................... 21
4.1 CLIMATE...................................................................................................................................... 21
4.2 ENERGY RESOURCE .................................................................................................................... 21
4.3 SOLAR ENERGY ........................................................................................................................... 21
4.4 ENERGY ACCESS ......................................................................................................................... 21
5 CONSULTATION AND PUBLIC DISCLOSURE .................................................................. 22
5.1 ESMF DISCLOSURE ................................................................................................................. 22
6 KEY RISK AND IMPACT MITIGATION ............................................................................. 23
6.1 INTRODUCTION ............................................................................................................................ 23
6.2 SOCIAL BENEFITS, RISKS, AND IMPACTS ..................................................................................... 26
6.3 POSITIVE E&S IMPACTS ............................................................................................................... 26

7 ROLES AND RESPONSIBLITIES OF IMPLEMENTING ENTITIES .................................. 28


7.1 PROJECT IMPLEMENTATION ARRANGEMENTS.............................................................. 28
Environmental and Social Management Framework (ESMF) i
Somali Electricity Access Project (SEAP) 2018

7.2 PROJECT IMPLEMENTATION ARRANGEMENTS BY COMPONENT .............................. 28


7.2.1 E&S Management Process for Component 1: Electrification of households and small
businesses through standalone solar home systems............................................................................ 28
7.2.2 E&S AREAS FOR COMPONENT 2: Analytical Work for Enabling Electrification Through
Solar Powered/Hybrid Mini-grids ...................................................................................................... 31
7.3 E&S AREAS FOR COMPONENT 3: Technical Assistance, Capacity Building and Project
Management............................................................................................................................................ 33
7.4 ROLE OF THE WORLD BANK ....................................................................................................... 33
8 SUB PROJECT SCREENING ................................................................................................ 34
8.1.1 Step 1. Applicability ........................................................................................................... 34
8.1.2 Step 2. Eligibility (Negative List) ....................................................................................... 34
8.1.3 Possible Environmental and Social Impacts ....................................................................... 34
8.2 SCREENING FORM ........................................................................................................................ 36
9 GRIEVANCE REDRESS MECHANISM ............................................................................... 37
9.1 PROCEDURES FOR COMPLAINTS.................................................................................................. 37
9.1.1 Registering Complaints ....................................................................................................... 37
9.1.2 Tracking, Investigating and Resolving Complaints ............................................................ 37
9.1.3 Gender sensitivity................................................................................................................ 38
9.1.4 Activating the GRM mechanism .......................................................................................... 38
9.2 GRIEVANCE REDRESS SERVICE ................................................................................................... 38
9.3 WORLD BANK INSPECTION PANEL ............................................................................................. 39
9.4 GRIEVANCE MECHANISM FOR WORKERS ................................................................................... 39
10 ESMF CAPACITY BUILDING AND TRAINING .............................................................. 41
11 ANNEXES ........................................................................................................................... 43
ANNEX 1: TEMPLATE FOR SUBPROJECT SCREENING ............................................................................... 43
ANNEX 2: SHS DISTRIBUTOR ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM: BASIC
REQUIREMENTS ....................................................................................................................................... 46
ANNEX 3 SAMPLE QUESTIONNAIRE FOR LITHIUM BATTERIES MANAGEMENT ........................................ 48
ANNEX 4 MINIMUM E & S REQUIREMENTS AND QUALIFICATIONS FOR SAFEGUARD CAPACITY UNDER
COMPONENT 1 AND 2 ............................................................................................................................... 49
ANNEX 5 STAKEHOLDER CONSULTATION, HARGEISA ......................................................................... 50
ANNEX 6 GRIEVANCE AND RESOLUTION FORM .......................................................................... 55
ANNEX 7 ENVIRONMENTAL CODE OF PRACTICE (ECOP) REQUIREMENTS ............................................. 57

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LIST OF TABLES
TABLE 3-1 INSTITUTIONAL ARRANGEMENTS IN ENVIRONMENTAL DECISION MAKING............................................18
TABLE 6-1 KEY E&S CHALLENGES AND MITIGATION .............................................................................................23
TABLE 6-2 POTENTIAL E&S RISKS AND IMPACTS .....................................................................................................24
TABLE 10-1 ESTIMATED BUDGET FOR TECHNICAL ASSISTANCE & IMPLEMENTATION OF ESMF ............................41

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Somali Electricity Access Project (SEAP) 2018

ACRONYMS AND ABBREVIATIONS

Abbreviation Description

ADRA Adventist Development and Relief Agency

BP Bank Policy

CAPEX Capital Expenditure

CEEH Candlelight for Environment, Education and Health

GM Grant Manager

CIP Capacity Injection Project

CPF Country Partnership Framework

DA Designated Account

DC Direct Current

DFID U.K. Department for International Development

DG Director General

EAFS External Assistance Fiduciary Section

ECoP Environmental Code of Practice

EIRR Economic Internal Rate of Return

ESMAP Energy Sector Management Assistance Program

ESMF Environmental and Social Management Framework

ESRES Energy Security and Resource Efficiency Programme

EU European Union

FCV Fragility, Conflict & Violence

FM Financial Management

GBOPA Global Partnership on Output-Based Aid

GDP Gross Domestic Product

GEEL Growth, Enterprise, Employment and Livelihoods

GHG Greenhouse Gas

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Somali Electricity Access Project (SEAP) 2018

Abbreviation Description

GIS Geographic Information System

GNI Gross National Income

GoSl Government of Somaliland

GRS Grievance Redress Service

HEIS Hands-on Expanded Implementation Support

HIPC Highly Indebted Poor Country

IA Implementing Agency

IDA International Development Association

IFC International Finance Corporation

IFI International Financial Institution

IPF Investment Project Financing

IPSAS International Public Sector Accounting Standards

ISA International Standards on Auditing

ISN Interim Strategy Note

JNA Joint Needs Assessment

LED Light Emitting Diode

LG Lighting Global

MoEM Ministry of Energy and Minerals

MPF Multi Partner Fund

NDP National Development Plan

NGO Non-governmental Organization

NIS Nordic International Support

NPP National Procurement Procedures

NPV Net Present Value

NRC Norwegian Refugee Council

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Somali Electricity Access Project (SEAP) 2018

Abbreviation Description

ODA Overseas Development Assistance

OP Operational Policy

OPEX Operating Expenditure

PAYG Pay As You Go

PDO Project Development Objective

PFM Public Financial Management

PFS Project Financial Statements

PHRD Policy and Human Resources Development

PIM Project Implementation Manual

PIU Project Implementation Unit

PP Procurement Plan

PPA Public Procurement, Concessions and Disposal Act

PPD Public Private Dialogue

PPF Powering Progress Fund

PPSD Project Procurement Strategy for Development

PSC Project Steering Committee

PV Photovoltaic

RE Recipient Executed

RISE Regulatory Indicators for Sustainable Energy

SBCF Somalia Business Catalytic Fund

SCD Systematic Country Diagnostic

SCoA Standard Chart of Accounts

SCORE Somali Core Economic Institutions and Opportunities

SDG Sustainable Development Goal

SDRF Somalia Development and Reconstruction Facility

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Somali Electricity Access Project (SEAP) 2018

Abbreviation Description

SEAP Somali Electricity Access Project

SET Somali Energy Transformation Project

SFMIS Somalia Financial Management Information System

SHS Solar Home System

Sida Swedish International Development Cooperation Agency

SORT Systematic Operations Risk-rating Tool

STEP Systematic Tracking of Exchanges in Procurement

TA Technical Assistance

TTL Task Team Leader

UCS Use of Country Systems

UNDB United Nations Development Business

UNDP United Nations Development Program

USAID United States Agency for International Development

WBG World Bank Group

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Somali Electricity Access Project (SEAP) 2018

EXECUTIVE SUMMARY

Introduction
This document presents the Environmental and Social Management Framework (ESMF) for the Somali
Electricity Access Project (SEAP) for the Government of Somaliland (GoSl). The ESMF ensures that the
project activities are compliant with the relevant requirements of national policies, regulations and
legislations as well as the World Bank Safeguards Policies and Procedures. The objective of this ESMF is
to set out the principles, rules, guidelines and procedure to assess the environmental and social impacts and
monitoring to ensure that environment and social aspects are duly considered.

This ESMF only applies to those activities that will be financed, either directly or indirectly, by SEAP, and
not to any other activities that a supported beneficiary may be otherwise involved in; all language in this
ESMF should be interpreted under this light.
Project Development Objective
The Project Development Objective is to expand access to electricity in targeted urban, peri-urban, and
rural communities in Somaliland.
The Project consists of three components as indicated below:
➢ Component 1: Electrification of households and small businesses through standalone solar
home systems
➢ Component 2: Analytical work for enabling electrification through solar powered/hybrid mini-
grids
➢ Component 3: Technical assistance, capacity building and project management

Project Description
Component 1: Electrification of households and small businesses through standalone solar home
systems
This component aims to reduce market barriers for the private sector to provide modern energy access
through solar home systems and targets (i) poorer households and small businesses in areas that cannot
afford to connect to mini-grid services; (ii) households and businesses in these areas that are not
sufficiently close to a mini-grid to be economically connected; (iii) isolated villages and smaller
settlements where mini-grids do not make economic sense; and (iv) nomadic pastoralists whose
livelihoods do not lend themselves to a fixed electricity connection.

This component will fund a range of market-building supply- and demand-side interventions in response to
these challenges. The proposed interventions (indicative allocations to each intervention are shown based
on initial analysis performed during project preparation, but are intended to remain flexible to react to
changing market needs) are:

a. Results-based Expansion Grants: (Results-based grants to off-grid solar distributors, with


payment based on the number of new Lighting Global-approved units sold. These grants will
provide distributors with much-needed capital to build internal capabilities, invest in sales and
distribution infrastructure, pilot new and innovative businesses and customer service models
(including pay-as-you-go models that enable customers to pay in installments, thus spreading out
payment over longer periods of time and improving affordability), and build up liquidity to act
as collateral for future debt finance from local banks. Expansion Grants will be primarily targeted

Environmental and Social Management Framework (ESMF) 1


Somali Electricity Access Project (SEAP) 2018

at businesses specializing in solar home system distribution, but could also be available to MFIs,
local savings cooperatives, or other institutions looking to enter the solar distribution market.

b. Upfront Seed Grants1: Since effective results-based financing requires that recipients have access
to sufficient inventory, funding, and capacity to self-finance initial sales, a complimentary
window will offer small upfront (i.e. paid in advance rather than results-based) Seed Grants to
support the relatively long tail of smaller or less experienced Somali distributors who are either
already active in the solar market or who might enter the market given additional incentives.
Seed grants will enable these businesses to build up a minimum of inventory and infrastructure
to launch sales and access the results-based Expansion Grant above. In addition, Seed Grant
funding will be used to provide a range of business development services (mostly through
external consultants) to early-stage Somali business in the off-grid solar sector, including support
on designing and implementing off-grid business models (especially pay-as-you-go), preparing
financial statements and projections, and connecting and negotiating with international off-grid
solar equipment suppliers, industry bodies, and other service providers. Application for Seed
Grant eligibility will be streamlined but will nonetheless entail a more rigorous evaluation
process since funding is awarded before results are achieved. The funding for Seed Grants is
expected to be made available by the Japan Policy and Human Resources Development (PHRD)
technical assistance program window.

c. Quality assurance: Interventions to limit the availability of and demand for poor-quality and/or
counterfeit products, including TA activities for national and regional governments, potentially
in preparation for eventual adoption of Lighting Global quality standards. The prolonged conflict
in Somali region and absence of quality control regulations, standards and policies has turned
the country into a hotbed of counterfeit products and dumping site of sub-standard goods. This
component will support the recently established Somali Bureau of Standards as well as quality
control initiatives in Somaliland, among others.

d. Consumer awareness: Comprehensive consumer awareness campaigns with the objective of


improving household understanding of how off-grid solar technology works, its benefits, how to
operate, maintain and dispose of the products, and the importance of quality in solar products
and how to identify them.

Component 2: Analytical work for enabling electrification through solar powered/hybrid mini-
grids

This component will support the mini-grid sector in Somaliland. The objective of this Component is to
focus on supporting activities that will establish a pipeline of mini-grid projects and define
delivery/business models for their implementation. This component is expected to include the following
activities:

a. Detailed geospatial mapping to undertake a more comprehensive inventorying of the current mini-
grid situation in Somaliland, identify potential future sites, and estimate future location-specific
demand
b. Review of property rights and land issues pertaining to energy infrastructure investment;

1 The financing of this sub activity would be provided in a separate grant under the Japan PHRD

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Somali Electricity Access Project (SEAP) 2018

c. Pre-feasibility studies for hybridization, operational enhancements, and densification of


brownfield (existing) mini-grid sites
d. Pre-feasibility studies for greenfield (new) sites identified in geospatial mapping
e. Developing structuring options for the financing, operation, and ownership of new mini-grids
f. Defining legal, institutional and financing arrangements for developing mini-grids.

Component 3: Technical assistance, capacity building and project management

This component will support a range of activities to strengthen the capacity of the Ministry of Energy and
Water Resources of the Federal Government of Somalia and the Ministry of Energy and Minerals in
Somaliland for overall energy sector management, power and access planning, and implementation of
future development projects. These activities will include targeted technical assistance in the form of: (i)
energy sector studies; (ii) development of energy sector strategies; (iii) review/finalization of energy
policies; (iv) additional analytical work; (v) improvement of respective internal ministry infrastructure
and systems; (vi) capacity building through trainings, workshops, and study tours; and (vii) supporting
the establishment of Project Implementation Units (PIUs) in the respective ministries to oversee
Component 2 and potential future IDA-funded projects (see Annex 2 for more details on implementation
arrangements and PIUs).

Capacity building activities funded under this component will be preceded by a detailed needs assessment
exercise in the first year of the project to identify priority interventions. This assessment will build on
initial capacity building and TA needs identified during project preparation and as part of the Power Sector
Master Plan currently under preparation. These include TA to develop national engineering standards for
power generation and distribution, developing a power sector regulatory framework, and training ministry
staff on key policy issues, including:
i. Preparing energy sector policy and planning;
ii. Preparing and promulgating tariff setting and licensing regulations for mini-grid
operators;
iii. Establishing engineering standards such as electrical wiring and installation codes;
iv. Setting health and safety standards for workers and consumers in the electricity sector;
v. Conducting feasibility studies;
vi. Performing resource mapping and working with GIS;
vii. Environment and safeguards; and
viii. Fiduciary/Procurement processes.

Project Beneficiaries

The Project aims to provide unelectrified Somali households and small businesses in urban, peri urban
and rural areas with affordable and reliable energy access. The project is expected to reach 41,000
households, equivalent to around 246,000 people, around 22.5% of the current off-grid population. Of
this number, 122,000 are expected to be women.
The project further aims to support the private standalone solar sector, which has become the main agent
of energy service provision, with little or no support from the government. Lastly, the project supports
the development of SMEs contributing to job creation in a nascent economy.

Project Environmental and Social Baseline


The specific locations of all SEAP related activities are not known at this time but it is expected that SEAP
related activities will be implemented in urban, peri-urban and rural areas of Somaliland. Chapter 4 of
Environmental and Social Management Framework (ESMF) 3
Somali Electricity Access Project (SEAP) 2018

this report describes the overall baseline condition of Somaliland in terms of biophysical environment and
the socio-economic context. Existing environmental and socio-economic conditions will, in many cases,
provide a basis for predicting impacts of the project components and sub-components. The project
activities will be implemented within premises of existing firms and will therefore not have any direct
interactions with indigenous people lands and territories.

Policy, Legal and Institutional Frameworks


Policy, legal and institutional frameworks with respect to the environment are currently under
development in Somaliland. Assessing the potential impact of such policies and regulations on the
environment, and how they could contribute to environmental conservation and sustainable livelihood
improvement, will therefore be ongoing.

In recent years Somaliland has effected a constitution within which article 12 addresses: Public Assets,
Natural Resources and Indigenous production. Although there are no Environmental Policy and Act in
place, an Environmental and Social Assessment Framework has been produced through the SDF program.
Protection and use of Somaliland water resources is the responsibility of the Ministry of Water Resources
that has put a policy, act and regulatory framework in place.

Safeguard Policies and Triggers


The project has been assigned “Category B Partial Assessment “as it is likely to have limited and
reversible environmental impacts, that can readily be mitigated. There are no significant and/or
irreversible adverse environmental issues anticipated from the activities to be financed under SEAP. The
ESMF has therefore been prepared to guide the selection and implementation of subprojects that will
require precautionary measures related to EA (OP/BP 4.01). Further, the project will comply with the
World Bank’s safeguard policy on Environmental Assessment (OP/BP 4.01), where potential risks and
impacts are anticipated. In this case, the project will implement alternative measures to avoid, minimize,
mitigate, manage or compensate adverse environmental impacts. Avoidance measures will be prioritized
over mitigatory or compensatory measures. Additionally the project will enhance positive impacts in
project selection, location, planning, design, implementation and management

Potential Environmental and Social Impacts of the Project


The core issue in regards to increasing the uptake of solar home systems (SHS) is the long-term
implication of the increased number of battery energy storage systems (BESS). This impact requires a
strategic solution through a program for battery disposal/recycling, in which SHS distributors play a role.
The entire management process including de-manufacturing, collection, storage, recycling, transport and
disposal may present a challenge to this project, given the scope of these management operations.
Additional risks would include weak labor practices among SHS companies, such as possible use of child
or forced labor, or inadequate occupational health and safety (OHS) practices.
Other project activities do not pose such or additional risks, since they relate to analytical work, technical
assistance, capacity building and training.

Monitoring and Mitigation Measures


In order to address the aforementioned potential adverse impacts, an environmental and social screening
process has been proposed under this ESMF, and will be applied in such a way as to ensure that potential

Environmental and Social Management Framework (ESMF) 4


Somali Electricity Access Project (SEAP) 2018

negative impacts of the project are prevented and/or mitigated appropriately, and positive impacts are
enhanced.

The activities envisaged under SEAP are low-risk. All products to be procured under the project must
adhere to the quality standards and testing methods developed by Lighting Africa/Global2. Criteria for the
selection of SHS companies to participate in the project will be developed and Lighting Africa/Global
compliance clauses will be included in funding agreements with the private sector. The criteria and
compliance to Lighting Africa/Global quality assurance frameworks will form the E&S requirements to be
established by the Grant Manager under component 1 of the project.

The Grant Manager will ensure qualified SHS companies sell and/or install SHS as per the funding
agreement and will be required to have an ESMS that will focus on key risks for this component (labor
issues, battery/waste management, and OHS issues).

The project will also be monitored to ensure that it puts adequate safeguards in place to address governance
issues. The project’s Task Teams will be required to consider as best practice, putting in place transparent
and accessible selection criteria that will ensure that companies owned by women, youth and people with
disabilities, have equal chance for consideration for funding under the project through the Grant Manager.

The ESMF incorporates aspects related to solid waste from solar PV systems and a project-specific
environmental code of practice (ECoP) has been developed as a guidance on approach for the collection,
transport, storage and disposal of spent batteries, with the aim of ensuring that risks to the environment and
human health are prevented or mitigated. Apart from providing approaches to the management of spent PV
batteries, the ECOP also seeks to inform discussion and build awareness of all stakeholders, including rural
community members, vendors/suppliers of products and service providers, around safe management of used
batteries.

ESMF Implementation Arrangements

The project will be implemented by The Ministry of Energy and Minerals (MoEM), Government of
Somaliland (GoSl). GoSl will competitively procure independent Grant Managers to manage the
Expansion Grants and Seed Grants under Component 1a and Component 1b. GoSl will be fully responsible
for procurement activities in order to foster project ownership, including preparation of Terms of
References, developing evaluation criteria for selection of firms, and review of deliverables. The Grant
Manager to be procured by the respective PIUs to manage Component 1a and Component 1b will have a
qualified Environmental and Social Management Specialist in his/her team in accordance with the
minimum qualifications provided for in Annex 4 of the ESMF. The E & S Specialist of the Grant Manager
will be responsible for the E & S screening of proposals for Component 1a and Component 1b and in
ensuring that the E & S requirements set forth in the ESMF for the grant recipients are complied with

Project Implementation Units (PIUs) will be established within the Department of Energy at the Ministries
of Energy and Minerals in Hargeisa. They will have the overall responsibility for project management,
coordinating project implementation, monitoring and evaluation and reporting of results to stakeholders
and developing environment and social safeguards frameworks and plans. PIU staff for the project will
either be seconded from government or hired as consultants, through a competitive process. Short-term

2 https://www.lightingglobal.org/where-we-work/lighting-africa/

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Somali Electricity Access Project (SEAP) 2018

local and international consultants will be recruited to support the PIU as needed. The capacity in the PIUs
will be enhanced through on-the-job training and mentoring by the Bank’s technical staff working on
fiduciary and safeguards and the task team leader. In areas such as procurement, it may be a challenge to
find a specialist already familiar with Bank policies and guidelines; as such, a procurement specialist from
an existing Bank-assisted project, SCORE, will be used in the interim while the project procures a specialist.
During implementation, an individual consultant will be hired for the first year of the project to the build
capacity of the new specialist. The implementing entities will develop a Project Implementation Manual
(PIM) to govern technical, financial and procurement functions of the project at the implementing agencies
level.

Safeguard arrangements have been developed for all Components 1, 2 and 3.

Component 1: Electrification of households and small businesses through standalone solar home
systems

Safeguard arrangements for component 1 will be implemented by the Grant Manager (GM). The GM will
screen and approve proposals for funding. The GM will set environmental and social (E&S) standards to
be met by grant recipients implementing activities under SEAP; and ensure the requirements are met during
the grant application, selection, agreement, and operationalization stage. During the grant agreement stage
the GM will ensure Environmental and Social Management Systems (ESMS), clean E&S track records,
and exclusion criteria are incorporated. During the operationalization stage, the GM will also conduct
periodic reviews and performance checks as needed, on a sample of the SHS companies, to assess their
ESMS and capacity to implement the safeguards arrangements.

The minimum E&S qualifications for the safeguard arrangements under component 1 are attached in Annex
4 of the ESMF.

Component 2: Analytical work for enabling electrification through solar powered/hybrid mini-grids

Component 2 will be implemented by the Project Implementation Units (PIUs). The minimum E&S
qualifications for the safeguard arrangements for this component are similar to those under component 1.
The minimum E&S qualifications for the safeguard arrangements under component 2 are attached in Annex
4 of the ESMF.

Component 3: Technical assistance, capacity building and project management


Component 3 will be implemented by the Project Implementation Units (PIU) which will implement
safeguard arrangement to ensure:
1) Safeguards-related support including setting health and safety standards for workers and consumers
in the electricity sector is provided;
2) World Bank safeguard policy requirements and World Bank Group Environmental, Health, and
Safety (EHS) Guidelines are met;
3) Short-term local and international consultants are recruited to support the PIU as needed; and
4) The capacity of the PIU is enhanced through on-the-job training and mentoring by the World
Bank’s technical staff working on fiduciary and safeguards, and the task team leader.

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Somali Electricity Access Project (SEAP) 2018

Public Consultations and Disclosure


The World Bank Safeguards Operational Policy /Bank Procedures OP/BP 4.01 Environmental Assessment
requires public consultation with affected groups and other stakeholders about the project
environmental/social impacts and take their view into account.
During the project preparation process, discussions were held on May 22, 2018 at the Ministry of Energy
and Minerals Main Conference Room in Hargeisa; and the main discussion points was the potential
positive and negative environmental and social impacts. Minutes of the consultations are documented in
Annex 5. The ESMF report will be disclosed on the ministry website as well as the World Bank InfoShop.

Cost Implications of the ESMF


Low capacity within the implementing agencies (Ministries of Energy) risks undermining the ability of
recipient-executed project activities to be rolled out in a timely and effective manner. To mitigate this
risk, the project will contribute to developing capabilities of sector institutions to oversee private-sector
led delivery of energy services. Technical capacities in the ministries are extremely limited; as such, a
third-party firm will need to be hired to administer the bulk of project activities on behalf of the
government under Component 1.

The ESMF has assessed the implementing agencies capacities and has proposed measures to enhance
safeguards capacity to improve environmental and social performance during project implementation; this
will include safeguards training for PIU. The budget proposed to enhance safeguard capacity is a total of
USD 110,000 for GoSl.

The budget will cater for capacity building of the PIU related to safeguard compliance, incorporate E&S
requirements (ESMS, clean track E&S record, applies Exclusion Criteria for SHS Companies, and
Contractors) into application, grant agreements and conduct review of SHS companies ESMSs, Monitoring
& Evaluation and Implementation of ESMF.
Grievance Redress Mechanism
The PIU will establish and manage a Grievance Redress Mechanism (GRM) to enable beneficiaries to
communicate their concerns regarding the Project. More specifically, the GRM will detail the procedures
that communities and individuals, who believe they are adversely affected by the Project or a specific
subproject, can use to submit their complaints. Further, it will also detail the procedures to be used by the
PIU and their implementing partners, to systematically register, track, investigate and promptly resolve
complaints.

The GRM is provided in section 9.

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Somali Electricity Access Project (SEAP) 2018

1 INTRODUCTION AND PROJECT CONTEXT

1.1 PROJECT CONTEXT


The Somali energy sector is one of the most underdeveloped in the region. Low electrification rates,
especially in rural areas, high cost of power, high technical and commercial losses, dependency on imported
petroleum products for electricity generation, and dependency on imported biomass resources for cooking
mean that only a very small fraction of the Somali population has access to affordable, safe, reliable, and
predictable energy services. Both public and private sector energy actors are highly capacity constrained,
and weak legal and regulatory frameworks, limited financing and investment, and lack of data for effective
decision making continue to hold back sector development.

The electricity access rate is estimated at 15 percent, meaning that around 11 million Somalis lack access
to electricity services. Access depends significantly on demographic variables, with urban access estimated
at 33 percent, and rural access at 4 percent. With an average household size of 5.9, this translates to
approximately 1.7 million un-electrified households nationwide. Private sector players supply more than
90 percent of power in urban and peri-urban areas using local private mini-grids, having invested in diesel-
based systems of between 500 kVA to 5000 kVA installed capacity per mini-grid. These mini-grids are
usually zoned, with each operator building, owning, and operating the generation, transmission, distribution
and maintenance, as well as collecting tariffs. Thus, more than 68 percent of urban/peri urban households
receive electricity service, though at a high cost that might reach a maximum of $1/kWh, making Somali
region one of the costliest places in the world to buy power. The latest ESMAP Regulatory Indicators for
Sustainable Energy (RISE) report found that Somali region ranks in the upper 5% globally for power cost,
and in the upper 15% globally for power expenditure as a share of GNI per household. As a result, access
levels remain low despite many households living near mini-grid power lines.

The proposed project aims to focus on improving energy access via standalone solar solutions for both
households and small enterprises given the country and sector context, as well as the modest financing
envelope. This will take the form primarily of providing a package of incentives to support local
entrepreneurs to develop new ventures or scale up existing activities. The project will especially target
existing “first movers” who have already demonstrated independent interest and capability in the solar
home systems sector. A smaller allocation for mini-grid activities will focus on studies aimed to
complement and build upon ongoing DFID and EU-led initiatives around this technology, and the findings
of the Master Plan that is currently under preparation with World Bank financing. The project will also
focus on building capacity within government agencies, while recognizing the need for robust third-party
support to deliver the project activities.

In addition to providing increased energy access, the project will set an invaluable precedent for Somali
energy sector development as well as international donor engagement. The project design draws on a
number of current best-practice off-grid interventions, including: (i) it constitutes a pilot engagement on
standalone solar home systems that is anticipated to further prove and develop the market for future public
and private sector engagement; (ii) it brings a public sector intervention to scale-up private sector delivery
of energy services; (iii) it contributes to the further scaling up the World Bank / IFC ‘Lighting Africa’ model
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for achieving off-gird electrification, particularly on quality assurance; and (iv), by mobilizing external debt
from private-sector financial institutions, it provides an important example of Maximizing Finance for
Development (MFD) implementation in a fragile context.

1.2 PROJECT DESCRIPTION

The Project will be implemented across the entire Somaliland. While there are tremendous needs with
respect to energy access, the fragile and complex operating environment necessitates a selective approach
to supporting the effective delivery of affordable and sustainable energy services. Somali’s private sector
has impressively stepped up to deliver basic energy services in the aftermath of the protracted conflict of
the 1990s. Nevertheless, these enterprises often lack the capital and latest technical, financing, and business
model insights to scale their businesses. The core proposition of this project is that by leveraging these
incumbent capabilities and activities, the overall quality of services they offer to their customers will be
improved, especially as they are provided with technical and financial resources needed to deepen and
broaden their geographic footprints.

1.3 PROJECT DEVELOPMENT OBJECTIVES

The Project Development Objective is to expand access to electricity in targeted urban, peri-urban, and
rural communities in Somaliland.

The PDO-level indicators are the following:

• People provided with new or improved electricity service (Core Indicator; 246,000 people); and
• Generation capacity of energy constructed or rehabilitated (Core indicator, 0.34 MW).

1.4 PROJECT BENEFICIARIES

The Project aims to provide unelectrified Somaliland households and small businesses in urban, peri
urban and rural areas with affordable and reliable energy access. The project is expected to reach
41,000 households, equivalent to around 246,000 people, around 22.5% of the current off-grid population.
Of this number o beneficiaries, 122,000 are expected to be women. These numbers would increase
substantially with co-financing from other donors, i.e. from the Japan Policy and Human Resources
Development (PHRD) technical assistance program window. Technology funded through the project will
provide an average of around 8W of generation capacity to each household reached, amounting to a total
of around 0.344 MW in expected new capacity. Rural areas in Somali regions are characterized by low
density of population, high levels of poverty, and nomadic lifestyles. These areas have extremely low or
no connectivity to electricity as they are not deemed economically feasible targets for grid extension.

The project aims to support the private standalone solar sector, which has become the main agent of
energy service provision, with little or no support from the government. There is very limited financing
or credit offered along the energy supply chain Importers are unable to access loans and therefore buy goods
with cash up front, limiting their ability to scale and reach new market segments. Manufacturers and

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foreign-based distributors perceive Somali businesses as high risk, and do not typically offer supplier credit.
For consumers, finance for solar off-grid products is undeveloped.

The project supports the development of SMEs contributing to job creation in a nascent economy.
Somali region has the building blocks in place to develop a strong private sector-based market for off-grid
solar products. There is a demonstrated demand and need for electricity and off-grid solar products, and a
variety of companies have already demonstrated strong capacity to reach off-grid consumers. Moreover,
there is also a strong foundation of entrepreneurial capacity among Somali business people and leaders that
can drive this initiative. Therefore, public resources will be used to harness private sector efficiencies by
creating appropriate incentives to mitigate the risks of doing business in the country. Such an initiative can
also create jobs directly contributing to economic productivity and security in the region.

1.5 PROJECT COMPONENTS

The proposed Project comprises of the following components and subcomponents:

• Component 1: Electrification of households and small businesses through standalone solar


home systems
• Component 2: Analytical work for enabling electrification through solar powered/hybrid mini-
grids
• Component 3: Technical assistance, capacity building and project management

1.5.1 Component 1: Electrification of households and small businesses through standalone


solar home systems
This component aims to reduce market barriers for the private sector to provide modern energy access
through solar home systems and targets (i) poorer households and small businesses in areas that cannot
afford to connect to mini-grid services; (ii) households and businesses in these areas that are not sufficiently
close to a mini-grid to be economically connected; (iii) isolated villages and smaller settlements where
mini-grids do not make economic sense; and (iv) nomadic pastoralists whose livelihoods do not lend
themselves to a fixed electricity connection.

The market for solar home systems in Somali region has significant potential. A study conducted in
preparation for this project estimated current demand at around 140,000 – 180,000 units for a total value of
around US$ 14 million per year. The total potential (non-annualized) market size for solar home systems
up to 500W was estimated at US$ 108.4 million, corresponding to around 1.1 million units, and US$ 79.6
million for systems up to 100W. This demand is further expected to rise as populations grow, off-grid
mobile phone usage increases, and more and more Somalis become aware of the potential benefits of solar
technology as a substitute or complement to conventional lighting sources such as candles, kerosene,
flashlights, and unreliable (mini-)grid connections.

Nonetheless, the current market situation remains well below its potential. The vast majority of sales to date
have come from low-quality, unreliable, and unsustainable imitation products. These are typically brought
in via the UAE or Oman as part of general goods orders by informal, non-specialized traders with limited
knowledge of quality solar products and few incentives to promote quality in a highly informal, unregulated,
and price-driven market. A small but growing supply side for quality-approved solar devices has begun to
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emerge as local entrepreneurs have started to capitalize on growing demand for more durable, higher-
performing products. To date, these distributors have managed to sell on the order of a few hundred systems
(partnering with subsidiaries of established providers of Lighting Global-certified off-grid solar home
system products), and have in some cases launched small initial pilots for alternative consumer financing
arrangements such as pay-as-you-go to tackle consumer affordability constraints for their products. In
addition to these dedicated off-grid distributors, a long tail of more generalist distributors continues to offer
off-grid lighting products of variable quality on a more opportunistic basis.

Though the early activity of these companies shows promise for the Somali off-grid market, local
distributors continue to face significant barriers to scale, including: (i) competition and market spoilage
from low-quality imitation products; (ii) low levels of consumer awareness around solar technology,
particularly regarding the long-term benefits of high-quality products and how to identify these; (iii) low
affordability among end-consumers, exacerbated by limited access to consumer finance; (iv) high costs of
rural distribution due to Somaliland’s large size, low population density, and poor transport infrastructure;
and (v) limited access to capital for inventory and investing in business infrastructure, as local banks still
prefer lower-risk, safer returns from more established industries.

Neither local nor international credit is currently available to Somali solar distributors due to the perceived
high risk of doing business in the country. There are several reasons for this, including: (i) unfavorable
loan terms and conditions; (ii) lack of capacity and limited understanding of customer needs amongst
financial institutions; and (iii) lack of competition among banks. Many individuals and businesses report
that they do not have enough or sufficiently reliable information for banks to assess their credit worthiness
and cannot meet banks’ strict collateral requirements to manage credit risk. As a result, businesses and
individuals are largely self-financing and circumvent the formal sector for their financial needs.

This component will fund a range of market-building supply- and demand-side interventions in response to
these challenges. The proposed interventions (indicative allocations to each intervention are shown based
on initial analysis performed during project preparation, but are intended to remain flexible to react to
changing market needs) are:

a. Results-based Expansion Grants: Results-based grants to off-grid solar distributors, with payment
based on the number of new Lighting Global-approved units sold. These grants will provide
distributors with much-needed capital to build internal capabilities, invest in sales and distribution
infrastructure, pilot new and innovative businesses and customer service models (including pay-as-
you-go models that enable customers to pay in installments, thus spreading out payment over longer
periods of time and improving affordability), and build up liquidity to act as collateral for future
debt finance from local banks. Expansion Grants will be primarily targeted at businesses
specializing in solar home system distribution, but could also be available to MFIs, local savings
cooperatives, or other institutions looking to enter the solar distribution market.

b. Upfront Seed Grants: Since effective results-based financing requires that recipients have access
to sufficient inventory, funding, and capacity to self-finance initial sales, a complimentary window
will offer small upfront (i.e. paid in advance rather than results-based) Seed Grants to support the
relatively long tail of smaller or less experienced Somali distributors who are either already active
in the solar market or who might enter the market given additional incentives. Seed grants will

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enable these businesses to build up a minimum of inventory and infrastructure to launch sales and
access the results-based Expansion Grant above. In addition, Seed Grant funding will be used to
provide a range of business development services (mostly through external consultants) to early-
stage Somali business in the off-grid solar sector, including support on designing and implementing
off-grid business models (especially pay-as-you-go), preparing financial statements and
projections, and connecting and negotiating with international off-grid solar equipment suppliers,
industry bodies, and other service providers. Application for Seed Grant eligibility will be
streamlined but will nonetheless entail a more rigorous evaluation process since funding is awarded
before results are achieved. The funding for Seed Grants is expected to be made available by the
Japan Policy and Human Resources Development (PHRD) technical assistance program window.

c. Quality assurance: Interventions to limit the availability of and demand for poor-quality and/or
counterfeit products, including TA activities for national and regional governments, potentially in
preparation for eventual adoption of Lighting Global quality standards. The prolonged conflict in
Somalia and absence of quality control regulations, standards and policies has turned the country
into a hotbed of counterfeit products and dumping site of sub-standard goods. This component will
support the recently established Somali Bureau of Standards as well as quality control initiatives in
Somaliland, among others.

d. Consumer awareness: Comprehensive consumer awareness campaigns with the objective of


improving household understanding of how off-grid solar technology works, its benefits, how to
operate, maintain and dispose of the products, and the importance of quality in solar products and
how to identify them.

The bulk of grant funding to businesses will be deployed in the form of results-based financing (RBF) under
the Expansion Grant. Well-administered RBF schemes are increasingly popular tools for both catalyzing
and cleaning up off-grid solar markets. They work by offering clear financial incentives to distributors for
the sale of high-quality (i.e., Lighting Global quality-verified) products on a first-come, first-served basis.
This incentivizes distributors to shift away from the sale of ineligible low-quality products, and to expand
their distribution networks to capture a larger share of the available funding. Distributors are also
incentivized to expand as rapidly as possible as funding is capped and not pre-allocated. There are a variety
of customization options available, including the specific formula for incentive calculations, the eligibility
criteria for firms and product sales, and reporting and after-sales service requirements. For instance, the
size of the incentive might be linked to the size of the system (as defined by SE4ALL’s multi-tier energy
access tracking framework) or whether sales are in urban or rural areas. Firms will be required to keep and
share complete records of product sales and commit to providing after-sales service that meets Lighting
Global requirements. An independent verification agent (IVA) will be tasked with ensuring companies meet
their obligations to customers and correctly report sales submitted to the Expansion Grant.

The Expansion Grants and Seed Grants will be managed by a single Grant Manager, but separate Grant
Managers will be procured for Somalia and Somaliland. Eligibility for grant funding will reflect regional
considerations (e.g. accessing RBF funds in one region will require evidence that the sale occurred in that
region). Procuring independent and experienced third-party Grant Mangers will address Government
technical capacity gaps, regional and clan dynamics, and the need to remain impartial and neutral in
delivering a successful project. Separate Grant Managers for the two territories will ensure ownership and

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capacity building for each of the respective governments. Grant Managers will also be required to provide
basic ongoing business development services to grant applicants to help strengthen applications and
business models and ensure grant funds are being used effectively. Grant Managers for both regions will
be expected to cooperate, exchanging market intelligence and information on prospective grant recipients
as needed.

Outcomes under these activities will be complemented and strengthened by the Somalia Capacity
Advancement, Livelihoods and Entrepreneurship through Digital Uplift Program (SCALED-UP)-P168115,
currently under preparation by the World Bank’s Finance, Competitiveness & Innovation (FCI) Global
Practice. SCALED-UP will work with local Somali banks to stimulate commercial lending to underserved
sectors (including the off-grid energy sector) through the provision of credit enhancement in the form of
guarantees and/or low-cost lines of credit. This enhancement will unlock private debt by buying down
lender risk in Somalia’s still nascent off-grid solar market. In addition, SCALED-UP activities will include
assistance to local banks in building a pipeline of both potential lenders and borrowers, making
introductions and linkages between banks and businesses, supporting distributors in making loan
applications, and supporting financial institutions in performing diligence and evaluating loan applications.
As limited access to debt for working capital is a crucial constraint for Somali off-grid companies, SEAP
will benefit greatly from enhanced participation of Somali banks in the off-grid sector. Conversely, funding
provided through the SEAP grants is expected to strengthen the financial position and growth prospects of
local solar distributors, thereby making them less risky clients for local banks. The SEAP team will closely
collaborate with FCI during SCALED-UP preparation and implementation to provide technical inputs and
ensure harmonization of approaches.

1.5.2 Component 2: Analytical work for enabling electrification through solar powered/hybrid
mini-grids
This component will support the mini-grid sector in Somaliland. The information available on existing
mini-grids is scant, even though they are the default energy provider throughout the country. While the
ongoing Power Master Plan Study (Master Plan), financed by the World Bank, will provide some clarity
regarding the status quo, additional sector studies will be required to define the appropriate way forward
for mini-grid technology. While the Master Plan will provide the long-term vision for the sector, key
development partners already have activities underway to support the scale up of mini-grids in Somaliland.
For instance, DfID supports the £20MSomalia. These include DfID’s £20 million ESRES Program, which
in its first phase is supporting the hybridization of six mini-grid sites with a £5 million budget. Phase 2 will
kick off in 2018 and will deploy the remaining £15 million. The EU has just completed another 6
community micro grid installations via the ADRA-implemented Somali Energy Transformation (SET)
Project. With the considerable activities currently underway by other donors, the objective of this
Component is to focus on supporting activities that will establish a pipeline of mini-grid projects and define
delivery/business models for their implementation.

To this end, this component is expected to include the following activities:

a. Detailed geospatial mapping to undertake a more comprehensive inventorying of the current mini-
grid situation in Somaliland, identify potential future sites, and estimate future location-specific
demand
b. Review of property rights and land issues pertaining to energy infrastructure investment;
c. Pre-feasibility studies for hybridization, operational enhancements, and densification of
brownfield (existing) mini-grid sites
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d. Pre-feasibility studies for greenfield (new) sites identified in geospatial mapping


e. Developing structuring options for the financing, operation, and ownership of new mini-grids
f. Defining legal, institutional and financing arrangements for developing mini-grids.

1.5.3 Component 3: Technical assistance, capacity building and project management


This component will support a range of activities to strengthen the capacity of the Ministry of Energy and
Minerals in Somaliland for overall energy sector management, power and access planning, and
implementation of future development projects. These activities will include targeted technical assistance
in the form of: (i) energy sector studies; (ii) development of energy sector strategies; (iii)
review/finalization of energy policies; (iv) additional analytical work; (v) improvement of respective
internal ministry infrastructure and systems; (vi) capacity building through trainings, workshops, and study
tours; and (vii) supporting the establishment of Project Implementation Units (PIUs) in the respective
ministries to oversee Component 2 and potential future IDA-funded projects.

Capacity building activities funded under this component will be preceded by a detailed needs assessment
exercise in the first year of the project to identify priority interventions. This assessment will build on
initial capacity building and TA needs identified during project preparation and as part of the Power Sector
Master Plan currently under preparation. These include TA to develop national engineering standards for
power generation and distribution, developing a power sector regulatory framework, and training ministry
staff on key policy issues, including:

ix. Preparing energy sector policy and planning;


x. Preparing and promulgating tariff setting and licensing regulations for mini-grid
operators;
xi. Establishing engineering standards such as electrical wiring and installation codes;
xii. Setting health and safety standards for workers and consumers in the electricity sector;
xiii. How to conduct feasibility studies;
xiv. Performing resource mapping and working with GIS;
xv. Environment and safeguards; and
xvi. Fiduciary/Procurement processes.

1.6 PROJECTS EXCLUDED FROM FINANCING


There are a number of other World Bank Environmental and Social Safeguards policies and procedures in
place to ensure identification and management of environment and social risks and impacts in the projects.
For the purposes of this project the companies involved in the following activities will not be supported by
the project.
• Proposals that will involve land acquisition, physical and economic displacement
• Production or activities involving forced labor
• Production or activities involving child labor
• Cross-border trade in waste and waste products, unless compliant to the Basel Convention and the
underlying regulations.

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2 SCOPE AND METHODOLOGY OF THE ESMF


2.1 ESMF JUSTIFICATION
The Environmental and Social Management Framework (ESMF) clarifies E&S management policies,
processes, and mitigation principles, organizational arrangements and design criteria to be applied to
subprojects, which are to be prepared during project implementation by PIU, Grant Manager and private
sector companies participating in the project.

PIU and the Grant Managers will use and refer to this ESMF during implementation of the Project. Where
appropriate, Environmental and Social Management Plans (ESMPs) will be prepared during project
implementation following guidelines in the ESMF. It remains the responsibility of the safeguards officers
of PIU and Grant Managers to ensure that the necessary mitigation plans are developed and adhered to by
the beneficiaries.

The specific objectives of this ESMF are:


• To ensure that the implementation of the project, for which the exact locations of the subproject
sites are not definitively identified at this stage, will be carried out in an environmentally and
socially sustainable manner.
• To provide information about scope of adverse E&S risks and impacts expected during subproject
planning, construction and operation; describe the approach to mitigation and monitoring actions
to be taken; and cost implications.
• To clarify the roles and responsibilities of PIU, Grant Managers and private sector companies and
operators for components 1 and 2 and other stakeholders with regard to E&S due diligence,
management of risks and impacts, and monitoring.
• To provide the project implementers with an E&S screening process and risk management
procedures that will enable them to identify, assess and mitigate potential E&S impacts of
subproject activities, including through the preparation of a site-specific Environmental and Social
Impact Assessments (ESIA) and/ or Environmental and Social Management Plans (ESMP) where
applicable

2.2 ESMF PRINCIPLE


This ESMF will guide the PIU in implementing the Project in line with World Bank and Somaliland
Government environmental and social management precepts. The ESMF will also guide the selection of
the GM and the implementation of safeguards under Component 1 by the GM.

2.3 METHODOLOGY
The ESMF was prepared through literature review and stakeholder discussions. The consultant undertook
a review of the Project Appraisal Document and Integrated safeguard datasheet (ISDS) for the SEAP, as
well as a review and analysis of relevant national legislation, policies, and guidelines, including the World
Bank Operational and Safeguards Policies related to this Project.

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Consultation with key stakeholders in the application and implementation of the ESMF for the Project was
conducted on May 22, 2018. The main points outlined in the consultative meetings with key stakeholders
are in chapter 5 and documentation in Annex 5.

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3 POLICY, LEGISLATIVE AND INSTITUTIONAL FRAMEWORKS


3.1 SOMALILAND LAWS AND LEGISLATIONS

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

In recent years Somaliland has effected a constitution within which article 12 addresses: Public Assets,
Natural Resources and Indigenous production. Although there are no Environmental Policy and Act in
place, an Environmental and Social Assessment Framework has been produced through the SDF program.
Protection and use of Somaliland water resources is the responsibility of the Ministry of Water Resources
that has put a policy, act and regulatory framework in place.

For Somaliland the institutions at National, Regional and District Levels responsible for the implementation
and monitoring compliance of both national and international agreements are shown below and include:

• The Minister, in consultation with the Parliamentary Environment committee and civil society
organizations working in the environment shall establish Environmental Watch Councils at
National level (NEWC).
• The Ministry of Environment and Rural Development (MoERD) in Somaliland in consultation with
Regional Authorities, the civil society at the Regional level and communities, shall establish the
Regional Watch Councils (REWC).
• The MoERD in consultation with the Local Government Councils/ District Governor, local
Community-Based Organizations (CBOs) and the community shall establish the District
Environment and Environment Watch Council (DEWC).
• The members of the Council shall come from both genders and should be Somaliland citizens in
good standing in the community and are environmentally conscientious. The council shall serve
five-year terms at a time and can be re-appointed.

The environmental licensing process in Somaliland is regulated by the Ministries. The key principles are:

• a. The MOERD (Somaliland) or any person authorized by him/her may grant any of the licenses
enumerated. Every license shall be subject to such conditions as may be specified therein.
• The Minister or any person authorized by him/her may at any time cancel or suspend any license
granted by or on behalf of the Minister, the holder of which has been on reasonable grounds
suspected by the Minister or such other authorized person, to have infringed any of the conditions
upon or subject to which said license has been granted, and may at any time vary the conditions of
any such license.
• Any person aggrieved by any order under this Article may appeal to the Minister of MOERD for
Somaliland whose decision shall be final.

The scope of activities requiring licenses include charcoal production, mining and quarrying, collection of
plants and grasses, collection of gums and resins, and investment projects including sectors such as waste,
wastewater, roads, and energy infrastructure.

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For the project implementation the E&S management will fully rely on WBG environmental and social
standards.

Table 3.1 gives a brief overview on roles and responsibilities on environmental management.

Table 3-1 Institutional Arrangements in Environmental Decision Making

Institution Mandate
Council of Ministers Approves National Strategic Climate Strategy
Parliament Approval of Environment Acts and Laws
Central Level • Prepares Strategic Climate, Environment
MoERD (Somaliland) and Social Strategy
• Environmental Policies / Plans
• Guidelines - Approves EAs
• Liaison with Regional level Institutions
• Monitoring and Evaluation

Regional Level: • Implement Regional Policies


Regional Environmental Watch Councils • Implement Sectoral Laws (National or State
(Somaliland) Laws) - Approval of all development
activities

Local Level: • Implement local orders on Public Health,


District Environmental Watch Council and Villages/ District natural resources
Pastoralist Community Environmental Watch • Implement Regional Laws
Councils (DEWC/ PEWC) • Approval of projects at District Level
• Mobilize local communities
• Submit requests for development activities
to REWC

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3.2 WORLD BANK SAFEGUARDS OPERATIONAL POLICIES


Relative to World Bank Environmental Safeguards, under Operational Policy (OP/BP) 4.01 the Bank
undertakes environmental screening and proposed projects are classified into one of four categories,
depending on the type, location, sensitivity, and scale of the project and the nature and magnitude of its
potential environmental impacts:
➢ Category A projects are likely to have significant adverse environmental impacts that are sensitive,
diverse, or unprecedented. These impacts may affect an area broader than the sites or facilities
subject to physical works.
➢ Category B projects may have potential adverse environmental impacts on human populations or
environmentally important areas but are less significant than those of Category A projects. These
impacts are site specific; few if any of them are irreversible; and in most cases mitigation measures
can be designed readily with standard methods.
➢ Category C projects are likely to have minimal or no adverse environmental impacts, and there are
no further environmental requirements.
➢ Category FI projects involve investment of Bank funds through a financial intermediary, in
subprojects that may result in adverse environmental impacts.

The Project is classified as Environmental Assessment Category B and triggers OP/BP 4.01 given that
potential impacts associated with financing of small-scale activities under components 1a and 1b. The
project receives this classification since project activities have the potential to cause localized negative
environmental impacts, which can be identified and managed using standard approaches. Projects and
activities have yet to be fully defined.

Under the Project, only one World Bank safeguard policy was triggered, namely the Environmental
Assessment Operational Policy (OP/BP 4.01).

Safeguard Policies Triggered Description and applicability


Environmental Yes The principal objective of OP/BP 4.01 is to ensure that World
Assessment (OP/BP Bank financed projects are environmentally sound and
4.01) sustainable. The policy is triggered if a project is likely to have
potential (adverse) environmental risks and impacts in its area
of influence. OP/BP 4.01 covers impacts on the natural
environment, human health and safety, and trans-boundary
and global environment.

In accordance with OP/BP4.01, This ESMF sets out the principles, rules, guidelines and procedures to
assess the environmental and social impacts. It contains measures and plans to reduce, mitigate and/or offset
adverse impacts and enhance positive impacts, provisions for estimating and budgeting the costs of such
measures, and information on the agency or agencies responsible for addressing project impacts.
No social impacts related to IPs or involuntary resettlements are anticipated under any of the activities
proposed for implementation under the three components of the project. This is because the activities will

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Somali Electricity Access Project (SEAP) 2018

be implemented within the premises of existing firms. For this reason, the project has not triggered the
Social Safeguard Policies, OP/BP 4.10 (Indigenous Peoples) and OP/BP 4.12 (Involuntary resettlement).

3.3 WORLD BANK GROUP EHS GUIDELINES


WBG has guidelines for Environment, Health and Safety (EHS) that serve as useful references for general
issues as well as sector-specific activities. Projects financed by the World Bank Group are expected to
comply with this guideline as required by the policies and the standards. The EHS guidelines are mainly on
occupational health and safety, community health and safety as well as on construction and
decommissioning. It contains guidelines cross cutting on environmental (waste management, ambient air
quality, noise and water pollution), occupational health and safety issues among others, applicable to all the
industry sectors.

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4 PROJECT BIOPHYSICAL AND SOCIOECONOMIC SETTING

4.1 CLIMATE
The Somali climate is hot, arid to semi-arid. There are two wet seasons (Gu April to June, and Deyr October
to November) with approximately 500 mm rainfall annually in the northern highlands, 50-150mm along
coast, and 300-500 mm in the southwest. With the impact of climate change extreme weather patterns such
as droughts and floods (see also natural disasters) are likely to increase in frequency and magnitude.

4.2 ENERGY RESOURCE


Somaliland is rich in energy resources, having unexploited reserves of oil and natural gas, untapped
hydropower, extensive geothermal energy resources, many promising wind sites, and abundant sunshine,
which can produce solar power. The major obstacles to development of these potentially available energy
resources are political, financial and institutional. Traditional biomass fuels such as firewood and charcoal,
primarily used in rural and poor communities, account for over 80% of the country’s total energy
consumption.

4.3 SOLAR ENERGY


Solar energy is abundant in Somaliland and is an increasingly popular option for rural communities,
individual businesses, and facilities. Horizontal solar energy is at least 200 W/m2 over most of the Somali
region, equalling roughly 200 kW/ km2. The Somali region gets on average 2,900 to 3,100 hours of sunlight
per year. It has one of the highest daily averages of total solar radiation in the world. The yearly average
solar radiation for Hargeisa is 6.4 kWh/m2 /day and the average yearly temperature in the country is 27°C,
a reasonable temperature to permit a satisfactory operation life of solar PV systems3.

4.4 ENERGY ACCESS


The electricity access rate is estimated at 15 percent. Access depends significantly on demographic
variables, with urban access estimated at 33 percent, and rural access at 4 percent. With an average
household size of 5.9, this translates to approximately 1.7 million un-electrified households nationwide.
Private sector players supply more than 90 percent of power in urban and peri-urban areas using local
private mini-grids, having invested in diesel-based systems of between 500 kVA to 5000 kVA installed
capacity per mini-grid. These mini-grids are usually zoned, with each operator building, owning, and
operating the generation, transmission, distribution and maintenance, as well as collecting tariffs. Thus,
more than 68 percent of urban/peri urban households receive electricity service, though at a high cost that
might reach a maximum of $1/kWh, making Somali region one of the costliest places in the world to buy
power. The latest ESMAP Regulatory Indicators for Sustainable Energy (RISE) report found that Somali
region ranks in the upper 5% globally for power cost, and in the upper 15% globally for power expenditure
as a share of GNI per household. As a result, access levels remain low despite many households living near
mini-grid power lines.

3Based on data from the European Commission’s African Renewable Energy Technology Platform (AFRETEP), http://capacity4dev.
ec.europa.eu/afretep/minisite/maps-and-data-sources. Calculations based on an average six-hour day of electrification in a 365-day year

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5 CONSULTATION AND PUBLIC DISCLOSURE


The World Bank Safeguards Operational Policy /Bank Procedures (OP/BP 4.01 on Environmental
Assessment requires public consultation with relevant stakeholders (potential project beneficiaries,
affected groups and local non-governmental organizations (NGOs) about the project environmental/social
impacts and take their view into account. Below is the process followed in stakeholder engagement and
disclosure plans.

Stakeholder engagement is important because it will give the project stakeholders and the potentially
Project Affected Person(s) the opportunity to contribute input and feedback information, aimed at
strengthening the development process and avoiding negative impacts or mitigating them where they
cannot be avoided. Effective and close consultation with them is a pre-requisite for the successful running
and execution of the SEAP.

The PMU will establish a grievance redress mechanisms (GRM) that will allow general public in the
project area, affected communities or individuals to file complaints and to receive responses in a timely
manner. The system will also record and consolidate complaints and their follow-up. This system will, be
designed for handling complaints perceived to be generated by the project or its personnel. It may also
include disagreements about compensation and other related matters.

Stakeholder‘s engagement and public consultation would be an on-going activity taking place throughout
the entire project process. Public participation and consultation would take place through meetings, radio
programs, requests for written proposals/comments, filling in of questionnaires, explanations of project
to the locals, making public documents available at the local levels.

During the project preparation process, discussions were held with the project implementing agency
(MoEM) on the project activities and components.

Minutes of the stakeholders consultations are documented in Annex 5

Consultations with stakeholders will be held continuously with the beneficiaries throughout the course of
project implementation.

5.1 ESMF DISCLOSURE


The Ministry of Energy and Minerals (MoEM), Government of Somaliland (GoSl) conducted meetings
with key stakeholders, SHS distributors’ representatives, household representatives, women, and the
communities. The objective of the meetings was to identify key issues and determine how the concerns of
all parties will be addressed.

The ESMF will be disclosed to stakeholders in Somaliland and on the World Bank’s external website, after
the World Bank review, as final draft versions. In-country disclosure of the ESMF will utilize appropriate
communication channels such as on the websites of the implementing agencies and/or as hard-copies in a
location and format easily accessible to public, and other public places of project intervention areas) as well
as on the World Bank external website.

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6 KEY RISK AND IMPACT MITIGATION


6.1 INTRODUCTION

The proposed activities under component 1 will involve plug and play solar systems as well as installed
solar systems where panels will be placed on the rooftops and within the existing property of households,
small business premises, or firms. These activities are expected to have limited, temporary and for the most
part reversible environmental and social impacts. No physical displacement or potential impact on
livelihoods is anticipated. Therefore, the World Bank Operational Policy on Involuntary Resettlement (OP
4.12) is not triggered, and the project will exclude any activity that will require land acquisition.

Component 2 activities will only focus on analytical work where a consultancy firm will be engaged to
carry out a pre-feasibility study that will identify and develop a pipeline of mini-grid projects to be financed
in the future.

Overall, the project will undertake consultations for broader stakeholder support, buy-in and ensure social
and gender-related considerations are met.

Specific E&S risks for each project component are mainly linked to processes and capacities of key
stakeholders for E&S risk management.
Table 6-1 Key E&S Challenges and Mitigation

Challenges Approach to mitigation


Decentralized project design with a • Environmental and Social Management Systems (ESMS)
large number of small subprojects requirements for SHS companies; differentiate ESIA and
prepared by private sector ESMP requirements based on E&S risk categorization;
implementing entities detailed and step by step E&S responsibilities for key
players for each project component
Lack of awareness on E&S risks and • Sensitization and dialogue via various methods of
impacts (communities, SHS stakeholder engagement
customers) • An ECOP (Annex 7) has been developed specifically for all
equipment to be financed under the project, namely solar
PV systems of generally in the range of 5 Watts. The key
environmental issue associated with the project is the
appropriate management and disposal/recycling of used Ni-
Cad and Lead Acid Batteries.
• The ECOP also covers health and safety during installation
and the, avoidance of land conflicts by requiring land owner
approvals for any use of third party land
Lack of capacity among private • Training for SHS companies
sector implementing entities
Battery disposal and recycling • Development of a strategic approach to SHS companies in
putting in place coherent battery storage, recycling, and
disposal practices (See Annex 2)

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Challenges Approach to mitigation


The core issue with the SHS • Labor and OHS practices of SHS companies would need to
component is the potential long-term be compliance with the World Bank EHS guidelines and
implications of the increased number good practice.
of the energy storage units
(containing batteries) that need to be
recycled.

Given the fragile context of the country, the low capacity of the Borrower particularly on safeguards, and
the potential social risks that might result from weak labor practices (child and forced labor) and OHS risks;
the overall E & S risk for the project is rated substantial.

Table 6.2 summarizes potential negative E&S impacts for each SEAP component. Beyond the mitigation
measures discussed below it will be important to adopt waste management principles (Source reduction,
reuse and recycling) at all time

Table 6-2 Potential E&S risks and impacts

Environmental Comment Impact Indicators Project Impact


Receptor/ Medium components
impacts are
relevant for
Battery disposal End of life battery OHS impacts on 1 High
disposal remains workers handing
the major risk battery recycling,
uncertified
facilities,
inadequate waste
disposal practices
Demography Demography of Changes in 1 Low
community in the demography,
Project‘s AoI gender ratio, age
distribution, socio-
economic structure,
etc. of the local
community
Utilities The existing Changes in existing 1 Moderate
utilities (e.g. power utilities
supply.) in the
Project‘s AoI

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Environmental Comment Impact Indicators Project Impact


Receptor/ Medium components
impacts are
relevant for
Infrastructure The existing Potential damage to 1 Moderate
infrastructure such road infrastructure;
as road, waste road traffic and
handling facilities, accidents;
etc. within the increased pressure
Project‘s AoI on waste
management
facilities
Employment/income The employment Opportunities for 1,2, and 3 Moderate
situation in the local employment;
Project‘s AoI changes in income
level
General public/ Labor influx and Increase in the 1,2 and 3 Low
project communities GBV demand for basic
services due to
temporary influx of
workers.
Increased crime
(including
prostitution, theft
and substance
abuse) to increase
in proposed sub
project areas as
influx of people
increases
Increased risk of
communicable
diseases (including
STI/ HIV/AIDs)
Construction Health and safety Accident, injury, 1 Low
workers of SHS Provider fatality, exposure to
employees. nuisance (dust,
noise), fire, etc.
Workplace health Health and safety Accident, injury, 1,2 and 3 Low
and safety of employees fire, explosion, etc.
involved in SHS
installation.
General public / Health and safety Accident, fire, 1,2 and 3 Low
communities of the general explosion
public

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6.2 SOCIAL BENEFITS, RISKS, AND IMPACTS


The project will have broad social benefits for households in rural, urban and peri-urban areas, as improving
households’ access to modern energy is central to restoring livelihoods and mitigating the impacts of the
crisis on the poor and most vulnerable.

Social risks associated with the potential exclusion of poor and vulnerable households, including female-
headed households and internally displaced people (IDP), will be mitigated by targeting rural and peri-
urban areas with particular attention paid to reaching first-time borrowers and by ensuring that
beneficiaries’ eligibility criteria will be transparent and part of the communication campaign. Risks
associated with the potential exclusion of small retailers from lists of prequalified suppliers will be
mitigated by relying as much as possible on the local supply chain and by targeting SMEs

6.3 POSITIVE E&S IMPACTS

• Reduced lighting costs to project beneficiaries: Electricity access will replace kerosene lamps
which are expensive to operate. Kerosene is costly both for low income households that buy it, and
for governments that subsidize it. In parts of Africa, for instance, kerosene costs make up 10-25%
of household monthly budgets according to a report by Lighting Africa market trends report 2013.
Comparing to these costs, the consumption electricity bills seem to be cheaper than using kerosene
for lighting significantly. Therefore, this project means greater savings on the part of the
households.

• Positive expected impact on poverty alleviation: With more affordable and stable electricity in
the otherwise off-grid areas, the beneficiaries will be engaging in income generating activities
hence improving their economic status.

• Provision of employment: Although minimal this project will have a positive impact on both
direct and indirect employment levels in the country translating into incomes at the household
levels which will trigger other spending and demand in the local economy.

• Improved standard of living: The implementation of this project will result in connecting about
28,700 to the off grid electricity. Access to electricity will change the standard of living of the
people as they can use domestic appliances like, fridges, television sets, to mention but a few. Use
of electricity for lighting implies that the people will not be exposed to smoke arising from use of
kerosene lamps which predisposes people to respiratory diseases.

• Communications: Access to electricity will lead to improved communication for the beneficiaries.
This will be enabled by the fact that charging of mobile phones will be easier and cheaper. Access
also to mass media like radio and T.V will provide opportunity for the households to access a wide
range of information which is useful for decision making.

• Gender Considerations: Electricity is a basic service especially for lighting but is still a luxury
for many rural women and men. Access to modern electricity will go a long way towards alleviating
the daily household burdens of women, giving them more time, improving their health and
enhancing their livelihoods. Available literature on gender and energy suggests that providing
electricity to communities and homes will promote gender equality, women‘s empowerment, and
women‘s and girls‘ access to education, health care, and employment. Indeed, most gender benefits
of the project will occur because women tend to spend more time at home, are responsible for
household chores that can be carried out more productively with electricity, and because certain
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tasks are culturally defined as women‘s work. The first and strongest impacts of the project shall
occur via lighting and TV.

Electricity will definitely displace more expensive candles and kerosene lamps, thereby reducing
indoor air pollution, fire, burn risk and providing higher quality light. Women and girls will benefit
more from air pollution of kerosene lamps because they spend more time in the kitchen. Lighting
and television will improve access to information, the ability to study, and extend the effective
working day. This is more so because children can have extended time of study. The women will
also benefit more due to access of information, especially on health and nutrition since they also
spend more time at home. The project will also enhance security in the rural areas as most homes
will be lit up, a benefit that is more appreciated by women.

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7 ROLES AND RESPONSIBLITIES OF IMPLEMENTING ENTITIES

The successful implementation of the ESMF depends on the commitment of PIU, the private sector and
related institutions, and the capacity within the institutions to apply or use the ESMF effectively, and the
appropriate and functional institutional arrangements, among others. The sections below describe the
detailed roles and responsibilities of the key institutions involved in the implementation of the ESMF by
project components.

7.1 PROJECT IMPLEMENTATION ARRANGEMENTS


Management of the Grant will be executed by GoSl. GoSl will competitively select a firm or consortium of
firms to provide the services under the scope of work of the Grant Manager. The individual subcomponents
under the Grants would be awarded to a single firm or a consortium. Consumer awareness and quality
assurance will be implemented by GoSl Somaliland. The Grant Manager will be expected to provide inputs
and guidance to these activities as necessary. The Grant Manager to be procured by the respective PIUs to
manage Component 1a and Component 1b will have a qualified Environmental and Social Management
Specialist in his/her team in accordance with the minimum qualifications provided for in Annex 4 of the
ESMF. The E & S Specialist of the Grant Manager will be responsible for the E & S screening of proposals
for Component 1a and Component 1b and in ensuring that the E & S requirements set forth in the ESMF
for the grant recipients are complied with.

Project Implementation Unit (PIU) will be established within the Department of Energy at the Ministry of
Energy and Minerals in Hargeisa. The PIU will have the overall responsibility for project management,
coordinating project implementation, monitoring and evaluation, and reporting of results to stakeholders
and developing environment and social safeguards frameworks and plans. PIU staff for the project will
either be seconded from government or hired as consultants, through a competitive process. Short-term
local and international consultants will be recruited to support the PIU as needed. Each PIU will have a
qualified E & S Specialist selected in accordance with the minimum qualifications set forth in Annex 4 of
the ESMF.

The capacity in the PIU will be enhanced through on-the-job training and mentoring by the Bank’s technical
staff working on fiduciary and safeguards and the task team leader.

PIU will also provide overall responsibility for safeguards due diligence, and compliance monitoring.
Further, PIU will be responsible for the overall coordination of the project implementation and oversight.
Grant Manager.

7.2 PROJECT IMPLEMENTATION ARRANGEMENTS BY COMPONENT


7.2.1 E&S Management Process for Component 1: Electrification of households and small
businesses through standalone solar home systems
This component aims to reduce market barriers for the private sector to provide modern energy access
through solar home systems to some of the households and small businesses in the Somali region without
electricity. The activity targets (i) poorer households and small businesses in areas that cannot afford to
connect to mini-grid services; (ii) households and businesses in these areas that are not sufficiently close to
a mini-grid to be economically connected; (iii) isolated villages and smaller settlements where mini-grids
do not make economic sense; and (iv) nomadic pastoralists whose livelihoods do not lend themselves to a
fixed electricity connection.

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This component will support the deployment of stand-alone solar systems ranging in different sizes and
levels of service. SHS standards are described in the SHS Operations Manual in detail.

Based on the qualification criteria established by Grant Manager GoSland submitted to the World Bank for
clearance; which include E&S requirements, SHS distributors will need to be qualified before they can
submit application for grants under this component. Once a SHS distributor becomes a qualified distributor,
it can then submit grant application, which once approved, will cover aspects of increase enterprise liquidity
by investments into business functions such as marketing, training, and after-sales support. Once the grant
agreement has been signed, the distributor will start the installation/distribution. Grant Manager is
responsible for verifying distributors ‘qualification, installation performance, overall compliance and
maintaining a GRM for both the public and the distributors for project related feedback.

The project will ensure that terms of reference for hiring the Grant Manager for implementation of
Component 1 contain clauses that relate to safeguards and occupational health and safety competencies
and specific tasks related to safeguard monitoring and enforcement. This will ensure safeguard capacity
within GM team to review beneficiary, applications, review and monitor the grants, and work in close
collaboration with the PIU safeguard focal person to manage the execution of the ESMF. The minimum
staffing qualification for GM safeguard capacity is provided in annex 4 of the ESMF. The selected
grant manager will be responsible for coordinating and supporting the implementation of safeguards
and will prepare a Project Implementation Manual (PIM) that will include a checklist for project
activities including potential threats, and mitigation measures as well as capacity building for
safeguards implementation and compliance monitoring. The Grant Manager will submit the PIM to the
GoSl for review, who will be required to submit to the Bank for clearance. Thus, any bidders for any
of the funding available under this component will have to indicate, in their respective bids, how they
intend to address environmental and social sustainability issues that could be associated with the
provisions of those services. The selected bidders will be responsible for implementing the safeguards
on the ground, including ensuring compliance with occupational health and safety imperatives and
dealing with de-manufacturing of out-of-use solar devices, e-waste disposal, and recycling.

Specifically, in terms of E&S risk management under component 1, the Grant Manager will be responsible
for:

• Overall oversight of the E&S risk assessment, management, and monitoring processes component
1 tools safeguard tools provided in this ESMF;
• Putting in place and implementing a reporting system from private sector entities to PIU on
implementation of E&S requirements;
• Ensuring that the private sector entities are implementing E&S component 1 requirements as set
out in the ESMF consistently;
• Assuming responsibility for citizen engagement, maintaining adequate stakeholder engagement
and grievance redress mechanism and ensuring that private sector entities maintain the same at their
level. The Grant Manager facilitate liaise with CBOs, NGOs and project affected communities;

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• Designing, organizing and implementing capacity building programs SHS distributors;


• Defining, jointly with the respective states and local governments, the project priorities based on
technical and policy development priorities;
• Resolving in consultation with the federal and regional governments challenges requiring high level
intervention facing the project; and
• Monitoring the implementation of the project in consultation with the federal and regional
governments.

The select Grant Manager will have safeguard capacity within its team to review beneficiary, applications,
review and monitor the grants. The GM will report to the PIU and the PIU will request for Bank clearance
on the implementation of safeguard requirement under component 1 by preparing regular consolidated
report on E&S performance of all subprojects.

The key players for ESMF implementation under component 1 will be the GM and the standalone solar
system (plug and play solar home system, or installed SHS) companies. GM roles during grant
application and operation stages are described in the sections below.

a) SHS DISTRIBUTORS Qualification Process

The Grant Manager will establish and publish the qualification criteria for SHS distributors to apply to
become ―Qualified Distributor under this project component. Specific E&S requirements are:

• Have a good E&S track record, meaning no E&S related fines, violation record, litigation, or
pending litigations in the past three years;
• Have an institutional ESMS that meets GM requirements – ESMS here is defined as a number of
key policies and procedures prepared and implemented by an SHS Provider (see Annex 2);
• Have the intuitional capacity to implement such ESMS; and
• Be willing to participate in E&S capacity building activities hosted by Grant Manager should GM
deems necessary.

Interested distributors can submit its completed Qualification Application Form and supply all required
documentation for application, including E&S documents, as part of application.
Grant Manager will review and verify the application before making the decision.

• Verify the adequacy of information submitted; and


• Maintain and address project related GRM issues

After verification, GM and the SHS distributer would sign the Grant Agreement, which should include clear
E&S requirements, such as:

• Distributor ‘s responsibility to maintain required policies in good standing; and


• Distributor will notify Grant Manager of any E&S issues affecting its compliance.
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b) SHS Distributor Operation


With the signed agreement, distributor will start install SHS per its terms as long as its operation remains
in good compliance with laws and all other E&S requirements.
Grant Manager will pay for qualified claims and maintain any project related GRM issues.

c) Post-Installation
After the SHS has been installed and is in use, the distributor is still responsible to maintain in good
compliance to overall requirements, provide good customer service, and participate in battery
disposal/recycle program.

Grant Manager’s duty to monitor operation and verify compliance include:

• Monitoring E&S compliance by independent company (under TOR for general monitoring of SHS
companies);
• Maintain project related GRM issues; and
• Prepare strategy for battery disposal / recycling (Lithium ion).

7.2.2 E&S AREAS FOR COMPONENT 2: Analytical Work for Enabling Electrification
Through Solar Powered/Hybrid Mini-grids

This component will support the mini-grid sector in Somaliland. The objective of this Component is to
focus on supporting activities that will establish a pipeline of mini-grid projects and define
delivery/business models for their implementation.

To this end, this component is expected to include the following activities:

• Detailed geospatial mapping to undertake a more comprehensive inventorying of the current mini-
grid situation in SomalilandSomalia, identify potential future sites, and estimate future location-
specific demand
• Review of property rights and land issues pertaining to energy infrastructure investment;
• Pre-feasibility studies for hybridization, operational enhancements, and densification of
brownfield (existing) mini-grid sites
• Pre-feasibility studies for greenfield (new) sites identified in geospatial mapping
• Developing structuring options for the financing, operation, and ownership of new mini-grids
• Defining legal, institutional and financing arrangements for developing mini-grids.

The consultant to be engaged for component 2 must have a safeguard capacity within its team. The
minimum safeguard staffing qualification within the consultant’s team is provided in annex 4 of the ESMF.
The role of the safeguard consultant under component 2 is, among others, to detail an E&S scope that will
mainstream following into the analytical work and output documents:

• E&S risks
• Potential mini grid placing or siting

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• Land acquisition
• Access
• Site selection process
• E&S Issues to be taken up during the subsequent phases

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7.3 E&S AREAS FOR COMPONENT 3: Technical Assistance, Capacity Building and
Project Management
Implementation of safeguards under component 3 will be the responsibility of the Project Implementation
Units (PIUs). To ensure the safeguards-related support, including setting health and safety standards for
workers and consumers in the electricity sector and the Bank safeguard policy requirements and WBG EHS
Guidelines are met, short-term local and international consultants will be recruited to support the PIU as
needed. The capacity in the PIU will also be enhanced through on-the-job training and mentoring by the
Bank’s technical staff working on fiduciary and safeguards and the task team leader.

7.4 ROLE OF THE WORLD BANK


World Bank will lay the benchmarks for all environmental and social safeguard issues concerned with the
development and implementation of SEAP. It will provide overall supervision, facilitation and co-
ordination of SEAP. It will also monitor funds and funds allocations; and project performance indicators.
The World Bank will assess the implementation of the ESMF and recommend additional measures for
strengthening the management framework and implementation performance, where need be. The reporting
framework, screening procedures and preparation of management and mitigation plans shall be discussed
and agreed by the Bank team and PIU during the early part of project implementation.

The GoSl will be responsible for the preparation of the ToRs that will be used during the implementation
of SEAP, and GoSl will be required to submit ToRs to the Bank for clearance, particularly including the
selection of the Grant Manager. As guided by ESMF, the ToR for GM will outline E&S actions to be
implemented by the GM against a proposed timeframe, and this will be reviewed by the PIUs.

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8 SUB PROJECT SCREENING

8.1.1 Step 1. Applicability


Project activities include works, as well as the purchase of goods and services. All works contracts that
will be supply and install, and all infrastructure goods, such as solar panels, will be installed by contractors
that are funded by the Project under a works’ contract.
The first step of screening is for the Grant Manager to determine the extent of potential direct and indirect
environmental and social impacts for each subproject. No further attention is required if the subproject is
unlikely to have direct or indirect environmental or social impacts.
8.1.2 Step 2. Eligibility (Negative List)
The second step is to determine if the subproject is eligible for financing under the Project. The Grant
Manager will identify, analyze and assess if the subproject is likely to have any of the following attributes:
Category A attributes, such as:
Activities with significant adverse impacts that are sensitive, diverse, or unprecedented, or
that affect an area broader than the sites or facilities subject to physical works
Major resettlement
Greenfield subprojects
Solid Waste
New disposal site
Income Generating Activities
Activities involving the use of fuelwood, including trees and bush
Activities involving the production or use of hazardous substances or explosives
Labor
Activities with potentially significant adverse impacts related to labor influx, child or forced
labor
Physical Cultural Resources, World Bank OP 4.11
Damage to cultural property, including but not limited to activities that affect:
• Archaeological and historical sites
• Religious monuments, structures, and cemeteries
Involuntary Resettlement, World Bank OP 4.12
• Activities requiring the involuntary taking of private land and relocation of PAPs
• Activities that require the relocation of encroachers or squatters

Subprojects with any of the above attributes will not be eligible for support under the Project.

8.1.3 Possible Environmental and Social Impacts


The Grant Manager will screen every subproject for environmental and social impacts using the following
checklist:

• Zoning and Land Use Planning


o Will the subproject affect land use zoning and planning or conflict with prevalent land
use patterns?
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o Will the subproject involve significant land disturbance or site clearance?


o Will the subproject land be subject to potential encroachment by urban or industrial use
or located in an area intended for urban or industrial development?

• Utilities and Facilities


o Will the subproject require the setting up of ancillary production facilities?
o Will the subproject require significant levels of accommodation or service amenities to
support the workforce during construction (e.g., contractor will need more than 20
workers)?

• Water and Soil Contamination


o Will the subproject require large amounts of raw materials or construction materials?
o Will the subproject generate large amounts of residual wastes, construction material
waste or cause soil erosion?
o Will the subproject result in potential soil or water contamination (e.g., from oil, grease
and fuel from equipment yards)?
o Will the subproject lead to an increase in suspended sediments in streams affected by
road cut erosion, decline in water quality and increased sedimentation downstream?
o Will the subproject lead to the destruction of vegetation and soil in the right-of-way,
borrow pits, waste dumps, and equipment yards?

• Noise and Air Pollution Hazardous Substances

o Will the subproject increase the levels of harmful air emissions?


o Will the subproject increase ambient noise levels?
o Will the subproject involve the storage, handling or transport of hazardous substances?

• Destruction/Disruption of Land and Vegetation

o Will the subproject lead to unplanned use of the infrastructure being developed?
o Will the subproject lead to long-term or semi-permanent destruction of soils in cleared
areas not suited for agriculture?
o Will the subproject lead to the interruption of subsoil and overland drainage patterns (in
areas of cuts and fills)?
o Will the subproject lead to landslides, slumps, slips and other mass movements in road
cuts?
o Will the subproject lead to erosion of lands below the roadbed receiving concentrated
outflow carried by covered or open drains?
o Will the subproject lead to long-term or semi-permanent destruction of soils in cleared
areas not suited for agriculture?
o Will the subproject lead to health hazards and interference of plant growth adjacent to
roads by dust raised and blown by vehicles?

• Expropriation and Social Disturbance


o Will the subproject impact internally displaced persons (IDP) negatively?
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o Will the subproject lead to induced settlements by workers and others causing social and
economic disruption?
o Will the subproject lead to environmental and social disturbance by construction camps?
o Will the subproject cause economic displacement?
o Will the subproject temporarily displace squatters, economically or physically, or other
informal groups?
o Will the subproject cause a loss in productive assets or income source?
o Will the subproject restrict access to resources?
o Will the subproject affect the livelihoods or vulnerable people, such as persons with
disabilities, widows or the elderly?
o Will the subproject create social conflict over the distribution of benefits or resources?

The Grant Manager or the focal points in the implementing partners might need to conduct field visits to
determine if any of the above impacts might be triggered. Any subproject triggering any of the above
impacts will require an Assessment of the triggered impacts, and a Plan to mitigate the specific impacts.

8.1.4 Management of E& S Impacts and Risk

Environmental and social safeguards instruments will be prepared where the screening checklist identifies
existence of the itemized risk in 8.1.3 above. Findings of this instruments will be collated together and
included in the project ESMP and C-ESMP. The implementing agency will be obligated to review and
comply with the developed ESMP and C-ESMP. These will be also be referenced and included in the
bidding document and the contracts to be executed between the implementing agencies and the grantees
and suppliers. The Bank and the implementing agency’s safeguards team will support and monitor the
ESMP and C-ESMP compliance through the project cycle and ensure it remains responsive to the project
risk.

8.2 SCREENING FORM


Within one week of receiving a draft subproject proposal, the Grant Manager will prepare and sign a
screening form (Template in Annex 1.) indicating if the ESMF is applicable to the subproject and if the
subproject triggers any of the attributes in the negative list.

The signed screening form will be passed on by the Grant Manager to the Program Manager and the
relevant subproject engineer for further processing.

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9 GRIEVANCE REDRESS MECHANISM

This chapter describes the Grievance Redress Mechanism (GRM) that the PIU and GM will establish and
manage to enable beneficiaries to communicate their concerns regarding the Project. More specifically, the
GRM details the procedures that communities and individuals, who believe they are adversely affected by
the Project or a specific subproject, can use to submit their complaints, as well as the procedures to
systematically register, track, investigate and promptly resolve complaints.

The PIU and GM will have the overall responsibility to address Project activity-related complaints from
Project affected communities or individuals regarding any environmental or social impacts due to
subproject activities. PIU/GM will recruit a dedicated focal point in its Office to handle Project activity-
related complaints. Each of the Implementing Partners will designate a GRM focal point.

9.1 PROCEDURES FOR COMPLAINTS


9.1.1 Registering Complaints
Access points for GRM focal point for beneficiaries to voice their concerns will be provided at the project
office. These access points will be advertised at subproject level, and include: complaint box with mail,
telephone, email and website.

Grievances can be brought up by affected people in case of: (i) non-fulfillment of contracts or agreements;
(ii) compensation entitlements; (iii) types and levels of compensation; (iv) disputes related to destruction
of assets or livelihoods; (v) disturbances caused by construction activities, such as noise, vibration, dust or
smell. Anonymous complaints will be admissible.
The Implementing Partners and Project contractors will also keep a log of issues brought directly to their
attention verbally or in writing by Project affected communities or individuals, and relay these concerns in
writing to PIU/GM on a next day basis. PIU/GM will determine if these concerns rise to the level of a
complaint.

PIU/GM will register the complaint in a dedicated log, including a copy of the complaint and supporting
documents. A draft template for registering grievances is found in Annex 6.

PIU/GM will record and document complaints received in the subproject file and the subproject progress
reports, including the number and type of complaints and the results of their resolution.

9.1.2 Tracking, Investigating and Resolving Complaints


The GRM log maintained by PIU/GM will track the date the complaint was received, date responded to,
the type of response, and if the complaint was resolved to the satisfaction of the plaintiff.
The GRM Focal Point will coordinate with implementing partners, local field staff and local government
officials to ensure prompt follow up action in response to each complaint. More specifically, the GRM
focal point will for named complaints:

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inform the plaintiff if the complaint is accepted or rejected within one week of receiving the
complaint; any technical input from Project engineers; if necessary the response will require
input from Project engineers
if the complaint is accepted, send the plaintiff an officially stamped review card indicating:
• plaintiff name or legal representative
• plaintiff address
• complaint title
• review date
• list of annexes submitted with the complaint
work with engineers, implementing partners, and contractors to resolve the complaint within 28
days of its submission

PIU/GM will include the log of complaints to the World Bank as part of PIU/GM quarterly reporting to the
World Bank.

9.1.3 Gender sensitivity


PIU/GM will make the GRM gender sensitive by recruiting female staff to:
• inform women about the Project and its possible benefits to women, in a culturally sensitive manner
• inform women of the Project’s GRM and its procedures
• receive any project-related complaints from women

9.1.4 Activating the GRM mechanism


PIU/GM will conduct a kick off workshop involving the implementing partners and beneficiary
representatives to inform them on GRM procedures.

9.2 GRIEVANCE REDRESS SERVICE


http://pubdocs.worldbank.org/en/440501429013195875/GRS-2015-BrochureDec.pdf
The World Bank’s Grievance Redress Service (GRS) provides an additional, accessible way for individuals
and communities to complain directly to the World Bank if they believe that a World Bank-financed project
had or is likely to have adverse effects on them or their community. The GRS enhances the World Bank’s
responsiveness and accountability by ensuring that grievances are promptly reviewed and responded to,
and problems and solutions are identified by working together.

The GRS accepts complaints in English or the official language of the country of the person submitting the
complaint. Submissions to the GRS may be sent by:

Email: grievances@worldbank.org
Fax: +1-202-614-7313
Letter: The World Bank
Grievance Redress Service (GRS)
MSN MC 10-1018
1818 H St NW
Washington, DC 20433, USA
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9.3 WORLD BANK INSPECTION PANEL


http://ewebapps.worldbank.org/apps/ip/Documents/Guidelines_How%20to%20File_for_web.pdf
The Inspection Panel is an independent complaints mechanism for people and communities who believe
that they have been, or are likely to be, adversely affected by a World Bank-funded project. The Board of
Executive Directors created the Inspection Panel in 1993 to ensure that people have access to an
independent body to express their concerns and seek recourse. The Panel assesses allegations of harm to
people or the environment and reviews whether the Bank followed its operational policies and procedures.

The Panel has authority to receive Requests for Inspection, which raise issues of harm as a result of a
violation of the Bank’s policies and procedures from:

• Any group of two or more people in the country where the Bank financed project is located who
believe that, as a result of the Bank’s violation of its policies and procedures, their rights or interests
have been, or are likely to be adversely affected in a direct and material way. They may be an
organization, association, society or other group of individuals;
• A duly appointed local representative acting on explicit instructions as the agent of adversely
affected people;
• In exceptional cases, a foreign representative acting as the agent of adversely affected people;
• An Executive Director of the Bank in special cases of serious alleged violations of the Bank’s
policies and procedures.

The Panel may be contacted by:


email at ipanel@worldbank.org
phone at +1-202-458-5200
fax at +1 202-522-0916 (Washington, D.C.)
mail at: Inspection Panel, Mail Stop MC 10-1007, 1818 H Street,
N.W., Washington, D.C. 20433, U.S.A.

9.4 GRIEVANCE MECHANISM FOR WORKERS


SHS as part of their ESMS will put in place a Grievance Mechanism for their workers that is
proportionate to their workforce, according to the following principles:

Provision of information. All workers should be informed about the grievance mechanism at the
time they are hired, and details about how it operates should be easily available, for example,
included in worker documentation or on notice boards.

Transparency of the process. Workers must know to whom they can turn in the event of a
grievance and the support and sources of advice that are available to them. All line and senior
managers must be familiar with their organization's grievance procedure.

Keeping it up to date. The process should be regularly reviewed and kept up to date, for example,
by referencing any new statutory guidelines, changes in contracts or representation.

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Confidentiality. The process should ensure that a complaint is dealt with confidentially. While
procedures may specify that complaints should first be made to the workers’ line manager, there
should also be the option of raising a grievance first with an alternative manager, for example, a
human resource (personnel) manager.

Non-retribution. Procedures should guarantee that any worker raising a complaint will not be
subject to any reprisal.

Reasonable timescales. Procedures should allow for time to investigate grievances fully but
should aim for swift resolutions. The longer a grievance is allowed to continue, the harder it can
be for both sides to get back to normal afterwards. Time limits should be set for each stage of the
process, for example, a maximum time between a grievance being raised and the setting up of a
meeting to investigate it.

Right of appeal. A worker should have the right to appeal to PIU or national courts if he or she is
not happy with the initial finding.

Right to be accompanied. In any meetings or hearings, the worker should have the right to be
accompanied by a colleague, friend or union representative.

Keeping records. Written records should be kept at all stages. The initial complaint should be in
writing if possible, along with the response, notes of any meetings and the findings and the reasons
for the findings.

Relationship with collective agreements. Grievance procedures should be consistent with any
collective agreements.

Relationship with regulation. Grievance processes should be compliant with the national
employment code.

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10 ESMF CAPACITY BUILDING AND TRAINING


The counterpart’s capacity in planning, implementing and supervising any due diligence measures
(environmental, social, technical and overall quality) is currently deemed very low. There is very limited
capacity in terms of staffing, financial resources and skills on the World Bank's safeguard policies. In
Somaliland, capacity within the Ministry of Energy and Minerals, which is responsible for energy sector
policy and oversight, and Ministry of Public Works, which supervises the Somaliland Electricity Agency
(SEA) have limited capacity to provide sector management, including in safeguards.

Despite the current low level of safeguard capacity within the agencies responsible for the power sector in
Somaliland, there is some nascent capacity in those government’s agencies responsible for environmental
matters. Given the relatively low to minimal level of environmental and social impacts anticipated by small-
scale solar installations under this project, the addition of one or two knowledgeable and engaged safeguard
specialists to a dedicated PIU or the staff of agencies responsible for electricity sector oversight could
adequately cover safeguard requirements for this project. Under Component 3, additional capacity building
for safeguard focal points and implementing agencies' technical staff could also serve as the base for
strengthening their safeguards oversight capacity for possible future larger power projects. The frameworks
will assess in more detail the staffing and capacity of the implementing agencies and propose a course of
action to fill the staffing and capacity gaps during implementation.

The ESMF has assessed the implementing agencies capacity and has proposed measures to enhance
safeguards capacity to improve environmental and social performance during project implementation; this
will include safeguards training for MOEM (SL). The budget proposed to enhance safeguard capacity is
110,000USD for GoSl.

The budget will cater for Capacity building of the PIU related to safeguard compliance, strengthening E&S
capacity, community engagement and sensitization, gender action implementation, battery recycling and
Implementation of ESMF.

The budget remains open for revision and improvement as and when needed. A breakdown of the budget
for GoSl is provided below.

Table 10-1 Estimated budget for technical assistance & implementation of ESMF

Activity Estimated Budget (USD)


Strengthening PIU Safeguard capacity 20,000
Battery recycling, Waste management, and more 20,000
specifically, battery storage and recycling; and need
for harmonization of E&S standards among SHS
distributors
Community engagement and sensitization 30,000
campaigns

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Activity Estimated Budget (USD)


Gender actions implementation. Implementing 40,000
gender strategy for the project by taking action for
women to be seen and engaged as valuable partners
along the entire value chain—in the design,
marketing, sales, and after-sale services
110,000

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11 ANNEXES

ANNEX 1: TEMPLATE FOR SUBPROJECT SCREENING

Subproject name
Subproject location
Implementing Partner
Is OP 4.01 applicable?
Is the subproject eligible (yes/no)?
Field Visit (yes/no; include date)
Observations/comments
Signature of Grant Manager

Applicability
Is the subproject likely to have direct or indirect environmental or social impacts?
Yes Continue to Step 2
No Go to bottom of page and sign the screening form

Eligibility (Negative List)


The subproject is ineligible if it has any of the following attributes. If this is the case, complete the
form and sign it.
Yes No
Category A attributes, such as:
• Activities with significant adverse impacts that are sensitive, diverse, or unprecedented, or that affect an area
broader than the sites or facilities subject to physical works

• Major resettlement

• Greenfield projects

Solid Waste

• New disposal site


Income Generating Activities
• Activities involving the use of fuelwood, including trees and bush.
• Activities involving the production or use of hazardous substances or explosives

Labor

• Activities a high risk of significant adverse impacts related to labor influx, child or forced labor.

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Physical Cultural Resources, World Bank OP 4.11


Damage to cultural property, including but not limited to activities that affect:

• Archaeological and historical sites


• Religious monuments, structures, and cemeteries

Involuntary Resettlement, World Bank OP 4.12

• Activities requiring the involuntary taking of private land and relocation of PAPs
• Activities that require the relocation of encroachers or squatters

Environmental or social impacts


Is the subproject likely to cause any of the following environmental or social impacts?

YES NO
A. Zoning and Land Use Planning
1. Will the subproject affect land use zoning and planning or conflict with prevalent
land use patterns?
2. Will the subproject involve significant land disturbance or site clearance?
3. Will the subproject land be subject to potential encroachment by urban or
industrial use or located in an area intended for urban or industrial development?
B. Utilities and Facilities
4. Will the subproject require the setting up of ancillary production facilities?
5. Will the subproject require significant levels of accommodation or service
amenities to support the workforce during construction (e.g., contractor will need
more than 20 workers)?
C Water and Soil Contamination
6. Will the subproject require large amounts of raw materials or construction
materials?
7. Will the subproject generate large amounts of residual wastes, construction
material waste or cause soil erosion?
8. Will the subproject result in potential soil or water contamination (e.g., from oil,
grease and fuel from equipment yards)?
9. Will the subproject lead to contamination of ground and surface waters by
herbicides for vegetation control and chemicals (e.g., calcium chloride) for dust
control?
10. Will the subproject lead to an increase in suspended sediments in streams affected
by road cut erosion, decline in water quality and increased sedimentation
downstream?
11. Will the subproject involve the use of chemicals or solvents?
12. Will the subproject lead to the destruction of vegetation and soil in the right-of-
way, borrow pits, waste dumps, and equipment yards?
13. Will the subproject lead to the creation of stagnant water bodies in borrow pits,
quarries, etc., encouraging for mosquito breeding and other disease vectors?
D. Noise and Air Pollution Hazardous Substances
14. Will the subproject increase the levels of harmful air emissions?

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15. Will the subproject increase ambient noise levels?


16. Will the subproject involve the storage, handling or transport of hazardous
substances?
E. Destruction/Disruption of Land and Vegetation
17. Will the subproject lead to unplanned use of the infrastructure being developed?
18. Will the subproject lead to long-term or semi-permanent destruction of soils in
cleared areas not suited for agriculture?
19. Will the subproject lead to the interruption of subsoil and overland drainage
patterns (in areas of cuts and fills)?
20. Will the subproject lead to landslides, slumps, slips and other mass movements in
road cuts?
21. Will the subproject lead to erosion of lands below the roadbed receiving
concentrated outflow carried by covered or open drains?
22. Will the subproject lead to long-term or semi-permanent destruction of soils in
cleared areas not suited for agriculture?
23. Will the subproject lead to health hazards and interference of plant growth
adjacent to roads by dust raised and blown by vehicles?
F. Expropriation and Social Disturbance
24. Will the subproject impact internally displaced persons (IDP) negatively?
25. Will the subproject lead to induced settlements by workers and others causing
social and economic disruption?
26. Will the subproject lead to environmental and social disturbance by construction
camps?
27. Will the subproject cause economic displacement?
28. Will the subproject temporarily displace squatters, economically or physically, or
other informal groups?
29. Will the subproject cause a loss in productive assets or income source?
30. Will the subproject restrict access to resources?
31. Will the subproject affect the livelihoods or vulnerable people, such as persons
with disabilities, widows or the elderly?
32. Will the subproject create social conflict over the distribution of benefits or
resources?

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ANNEX 2: SHS DISTRIBUTOR ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM: BASIC


REQUIREMENTS
This document provides basic requirements for the institution’s Environmental and Social Management
System (ESMS) for SHS distributors who are interested in being qualified for the SEAP Component 1.
There are three basic requirements for the institutional management of E&S issues, which also requires the
SHS Provider to commit sufficient resources and capacity to implementation.

Human Resources Policy

SHS Provider will have in place an HR policy that expresses its commitments, at a minimum to: (1) comply
with all relevant national labor laws and regulations; (2) promote the fair treatment, non-discrimination,
and equal opportunity for workers; (3) establish, maintain, and improve the worker-management
relationship; (4) allow workers‘ organizations and collective bargaining; (5) have in place a grievance
mechanism for workers; (6) not to employ forced labor or child labor, including not hiring workers below
minimum age, as defined by national law and not employ children in hazardous work4.

SHS Provider will adopt and implement human resources policies and procedures appropriate to its size
and workforce that set out its approach to managing workers consistent with the requirements of national
law. It will provide workers with documented information that is clear and understandable, regarding their
rights under national labor and employment law and any applicable collective agreements, including their
rights related to hours of work, wages, overtime, compensation, and benefits upon beginning the working
relationship and when any material changes occur. It will provide and inform workers of an internal
grievance process to raise their workplace concerns.

Collection of Batteries by SHS Companies: SHS Provider representatives will make arrangement to
collect the battery units from the consumer and store it in the local offices. SHS Provider will take necessary
measures to ensure safe storage of the batteries. It may be feasible for SHS Provider to send the warranty
expired batteries to a central location.

Potential battery disposal / recycling options can be as follows:

Buy-back arrangements with manufacturers: SHS Provider can put in place buy-back arrangements
with the battery manufacturers and ensure safe transportation of the batteries to the manufacturer. SHS

4 Employees may only be taken if they are at least 15 years old, as defined in the ILO Minimum Age
Convention (C138, Art. 2). Children under the age of 18 will not be employed in hazardous work. Children
will not be employed in any manner that is economically exploitive, or is likely to be hazardous to, or to
interfere with, the child's education, or to be harmful to the child's health, or physical, mental, spiritual,
moral, or social development

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Provider and manufacturers can mutually decide on cost sharing of collection and transportation of expired
batteries, for example sign a Memorandum of Understanding signed between them;

Recycling at own facilities: SHS companies may consider establishing their own recycling facilities.
Recycling of lithium ion batteries is possible but, according to research and practice, makes little economic
sense. Lithium ion batteries can be recycled, but only at specified locations. Projects are currently underway
in Europe, the United States and Japan to develop effective and feasible recycling technologies with a
complete life cycle analysis of recycling;

Recycling at centralized locations in the country: If recycling facilities for lithium ion batteries exist,
SHS companies must use those that meet Lighting global SHS quality standards and are considered safe
and complainant with national regulations and World Bank standards;

Disposal: Lithium ion batteries may qualify as household hazardous waste. SHS Provider will ensure that
the batteries are disposed in a particular designated area ensuring environmental and occupational health
and safety in line with World Bank E&S standards and Environmental, health, and Safety Guidelines of the
World Bank Group. SHS Provider will also comply with the government regulations, if any, regarding
disposal of any of the components used in the battery units

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ANNEX 3 SAMPLE QUESTIONNAIRE FOR LITHIUM BATTERIES MANAGEMENT


Name of Respondent:
Location:
Phone Number:

QUANTITIES AND COSTS OF LIBs:

a) How many LI batteries do you need to power a solar panel?


b) How do you intend to process used LI batteries?
c) How much do you buy?
d) Do you supply to others in the sector?
e) How do you sell and to whom?
f) How are LI batteries delivered to you?
g) How are they transported and what is your storage capacity?
h) How much does it costs to store LIB?

END PRODUCT OF LIB RECYCLING:

a) What products do you intend to extract from the LI battery?


b) Do you have already established process that could be applied?
c) Do you intend to sell the end product locally or internationally?
d) To whom do you intend to sell these end products?

3. HEALTH, SAFETY AND POLLUTION CONTROL

a) Would you consider this business dangerous to your health and environment?
b) How long have you been in this business?
c) Have you observed any health challenges?
d) What other waste does the business produce?
e) How do you intend to dispose or manage the (se) other waste(s)?

4. WILLINGNESS TO INNOVATE AND MODERNIZE

a) Do you think your current practice meet international best practice?


b) Are you in discussion with your supplier for a buy back mechanism?
c) What aspects of your business particularly the end of life battery management do you think can be
developed further to assist you?
d) In your estimation, how big do you think LIB recycling would become?
e) How many persons do you employ currently?
f) What are your major challenges

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ANNEX 4 E & S REQUIREMENTS


MINIMUM AND QUALIFICATIONS FOR SAFEGUARD CAPACITY
UNDER COMPONENT 1 AND 2

The below criteria will be included in the ToRs for component 1 and component 2 for minimum safeguard
staffing qualifications within the consultants’ teams.

The safeguard resource shall have at least a Masters’ degree in Environmental Science/Environment
Studies/Environmental Engineering or related discipline with a minimum of 5 years of experience in
environmental management and report preparation; thorough understanding of the legislative and
regulatory requirements of Somaliland, World Bank operational policies and proven report writing skills.

The candidate should also have:

• Experience in implementing the international environmental risk management policies/standards


and well conversant with multilateral agencies requirements;
• Knowledge and/or familiarity with the country's geography and specifically the issues in the
project’s area;
• Thorough and proven knowledge and practical experience of assessing environmental issues related
to renewable projects, and more specifically solar projects;
• Ability to work well with Government officials and community personnel;
• Deep knowledge in environmental management framework of local governments;
• Strong and demonstrated capacity for organization, management with excellent reporting and
coordination skills;
• Strong leadership, technical competence and professional skills for timely implementation,
coordination and management of activities;
• Ability to work in a team, develop synergies and establish effective working relations with various
stakeholders;
• Strong interpersonal and communications skills, resourcefulness, initiative, tact and ability to cope
with challenging situations;
• Excellent command in English language (both spoken and written) and communication skills
(Somali language prowess will be an added advantage)
• Have robust knowledge of institutional systems for the environmental review and approval of
development projects in the country;

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ANNEX 5 STAKEHOLDER CONSULTATION, HARGEISA


MINUTES OF ENVIRONMENTAL SOCIAL MANAGEMENT FRAMEWORK
(ESMF) CONSULTATION FOR SOMALI ELECTRIFICATION ACCESS PROJECT
(SEAP)
Date 22nd May 2018 Time 9:00 am to 11:00 am
Venue Ministry of Energy and Minerals Main Conference Room
Agenda 1. Remarks
2. Concerns/ Issues from participants
3. Responses

Conclusions 4. No follow up actions identified

Topic Comments
Min 1/18 Remarks
Welcome address and H.E DG Abdirahman acknowledged to the Department of energy for
introductions developing and organizing the ESMF presentation and stakeholder
H.E Engineer consultation. The DG introduced the ESMF and its importance for the
Abdirahman Abdeeq, Somali Electricity Access Project which is going to start in 2018.
Director General of
Energy and Minerals
ESMF Expectations and Outcomes were described and participants
invited to provide their feedback and recommendations.
Some of the expectation of the ESMF included:
1. To provide information about scope of adverse E&S risks and impacts
expected during subproject planning, construction and operation,
describe the approach to mitigation and monitoring actions to be taken;
and cost implication, provide the project implementers with an E&S
screening process and risk management procedures that will enable them
to identify, assess and mitigate potential E&S impacts of subproject
activities
Eng. Guled Ahmed Eng. Ahmed presented the ESMF and elaborated in greater detail the major
Energy Technical issues as follows:
Consultant 1. Environmental and social management framework purpose
2. The specific objective of the ESMF
3. Somaliland electricity access project components and beneficiaries
4. Safeguard policy and triggers
5. Positive impacts of the project
6. Negative impacts of the project
7. ESMF implementation
8. Grievance and redress mechanism

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9. Sub project screening applicability


10. Environmental code of practice
11. Environmental and social management system
Min 2/18 Concerns / Issues and suggestions shared by the participants
1. Shared that they have collection points for e-waste for disposal by
companies in the recycling industry.
2. Commented on their experiences in projects where environmental
impact assessments are conducted prior to project implementation and
on the importance of these assessments.
3. Concerns from previous projects was that a negative environmental
impact was the large land area dedicated to solar system installations.
Specifically, some projects fence large areas of land while using much
less land area for the solar PV installation.
4. The need to build the understanding and capacity of project
participants and beneficiaries on the solar systems and their use in
order to prevent environmental risks were highlighted.
5. There was a query on whether there is a budget to mitigate
environmental impacts during project implementation.

Some participants indicated their willingness to participate in the project in


line with any environmental and social requirements for project
implementation.
Min 3/18 Responses given
1. Budget – the budget amount required for implementation of the
ESMF had been identified
1. Environmental and social safeguards: arrangements and processes
have been outlined in the SEAP implementation youth and women
groups will be given priority at the procurement and recruitment
process.
2. Battery and other waste materials recycling and/or disposal will be
handled as per ESMF and the capacity to implement the arrangements
will be developed over time.
3. Dissemination: The documents will subsequently be shared by email to
the participants.
4. Land Use: There will be no land acquisition or land use for solar PV
installation as the mini-grid component of SEAP will only focus on
analytic work.
5. Awareness creation: The project will implement activities to raise
awareness of the community in terms of economic growth and
improvement in living standards through sustainable use of solar PV
systems.

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Response from the Ministry of Environment: The Ministry concluded that


the potential negative impact of this project is very limited. The Ministry
expressed its appreciation of renewable energy projects and particularly
SEAP’s focus on sola because it doesn’t have any environmental impact.
The Ministry is encouraging environmentally friendly projects which reduce
pollution and carbon emissions.
Closing remarks: Eng. The DG thanked participants for taking the time to attend the productive and
Liban Mohamed fruitful consultative meeting.
A. O. B The DG will contact participants and invite them to an induction meeting for
SEAP, after June 2018.

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The Environmental Social Management Framework (ESMF) consultation


meeting for Somali Electrification Access Project (SEAP)
Attendance sheet
Date: 22/05/2018
Venue: Ministry of Energy and Minerals Main Conference Room
Start time: 9.00 am
Meeting ended: 11.00 am

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ANNEX 6 GRIEVANCE AND RESOLUTION FORM

SAMPLE GRIEVANCE AND RESOLUTION FORM


Name (Filer of Complaint): __________________________________
ID Number: __________________________________ (PAPs ID number)
Contact Information: _____________________________District/Community mobile phone)

Nature of Grievance or Complaint:


_____________________________________________________________________________________
_________________________________________________________

Date Individuals Contacted Summary of Discussion


____________ __________________ ___________________________

Signature_______________________ Date: ____________

Signed (Filer of Complaint): ______________________________________


Name of Person Filing Complaint: __________________________ (if different from Filer)
Position or Relationship to Filer: __________________________________

Review/Resolution
Date of Conciliation Session: ______________________________________
Was Filer Present? Yes No
Was field verification of complaint conducted? Yes No
Findings of field investigation:
_____________________________________________________________________________________
_________________________________________________________________

Summary of Conciliation Session Discussion:


_____________________________________________________________________________________
_________________________________________________________________

Issues:
___________________________________________________________________________

Was agreement reached on the issues? Yes No


If agreement was reached, detail the agreement below:
If agreement was not reached, specify the points of disagreement below:

Signed (Conciliator): ___________________________ Signed (Filer): ________________

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Signed: ___________________________
Independent Observer

Date: ___________________________

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ANNEX 7 ENVIRONMENTAL CODE OF PRACTICE (ECOP) REQUIREMENTS


Batteries and potential environmental impacts

A central component of any remote solar power system such as those used in ‘plug and play’
systems and proposed under Component I of the Project is the use of rechargeable batteries. These
batteries store the power generated during the daylight hours for later use. Rechargeable batteries
include lithium ion Li-ion), nickel metal hydride (NiMH), nickel cadmium (Ni-Cad) and lead acid
batteries (LAB).

Accordingly, this ECOP applies specifically to LAB and Ni-Cad batteries. These batteries, if
improperly transported, stored and disassembled/recycled, can create long lasting environmental
impacts due largely to the chemical and heavy metals such as mercury, lead, cadmium and nickel
which are central components of these batteries. If released into the environment (via incineration
and/or leakage and leeching etc.) these chemicals and heavy metals can create a number of health
impacts including headaches, abdominal discomfort, seizures and comas. The main components
of a lead-acid battery are lead (Pb) electrodes and lead dioxide (PbO2) electrodes immersed in a
solution of water and sulphuric acid. These are generally contained in a plastic case made from
polypropylene. In addition to lead which can create to a wide range of biological effects (including
upon the kidneys, gastrointestinal tract, reproductive system and the nervous system) and is a
recognized developmental and reproductive toxicant1, lead acid batteries also contain sulfuric acid
which is highly corrosive and can cause burns and damage to skin, eyes or the respiratory system.
Both nickel and cadmium which are the central components to Nickel-Cadmium (Ni-Cad) batteries
have potential negative impacts on both the environment and on human health. While the effects
of nickel are generally less severe (in the absence of long term exposure to airborne nickel dust)
and limited to skin irritations, cadmium is a carcinogen, which can lead to renal dysfunction and
bone defects. Effective management of batteries can ensure that these potential negative impacts
are not realized as a result of this Project. Indeed, through the increased awareness activities
proposed, it is expected that the project, guided by this ECOP, will have the potential to have long-
term positive impacts on communities and public health since many batteries of this type are used
by these communities outside this project.

Battery Management Approach

The approach adopted seeks to avoid the potential environmental impacts created by improper
management of LAB and Ni-Cad batteries. Mitigation measures proposed comprise two
fundamental stages or approaches namely (i) Community and user awareness and (ii) Direct
management of used nickel cadmium (Ni-cad) and lead acid batteries (LABs) by the system
suppliers.

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Community and user awareness

As part of an initiative of informing the community of the risks associated with batteries under this
Project, the PIU will carry out a broad battery awareness campaign. This campaign will not only
focus on project participants and beneficiaries. Instead, the campaign will target all community
members and as such will result in improved knowledge of the environmental issues associated
with spent batteries, whether they are from people’s cars, or other power supplies etc. Importantly,
the communication campaign will include information on all the main battery types, irrespective
of whether they are high toxicity (such as NiCad and LAB) or lower toxicity batteries (such as
AA, or AAA batteries etc). The type of information to be included in the information campaign is
included in Annex.

A campaign will be designed by the Project; however, it is expected that it will include initiatives
such as:
• Information on the implementing agencies website on disposal of all battery types;
• Appropriate local information campaigns including distribution of flyers and information
sheets in local communities, awareness raising at community meetings and notices at shops
selling batteries; and
• A media campaign including advertisements and awareness pieces in local newspapers.

This campaign will run for the life of SEAP and will address issues such as:

- The differences between the battery types in terms of battery life and reliability;
- The safe handling of batteries including installation, removal, transport, storage and
disposal;
- The environmental and health aspects of poor battery disposal; and
- Focused information on the environmental and health issues associated with high toxicity
batteries and explanation as to why they must be stored, transported and disposed of in
certain ways and therefore why it is in the interests of individuals, the community, the
environment (and therefore future generations in communities) that the methods outlined
in this ECOP be followed.

Direct management of used nickel-cadmium (Ni-cad) and lead acid batteries (LAB) by
the system suppliers

The disposal and management of used batteries from solar PV systems will follow the provisions
of this ECOP, which is to require the vendors of the systems to make arrangements to collect used
Ni-Cad and LAB batteries and to properly dispose of them. Notwithstanding this, the direct

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management process outlined below is focused on Li-ion, nickel-cadmium (Ni-cad) and lead acid
batteries (LABs) as these batteries represent the greatest risk to human and environmental health
if incorrectly managed. The vendors will provide a Battery Management Plan which details
arrangements for the collection, transport, storage and disposal of batteries for those systems
proposed to be eligible under the Project as part of the product registration process. The DoE will
assess these processes for compliance with the guidelines set out in this ECOP and may refuse to
register vendors’ products if they do not comply with the guidelines. A vendor may be refused
registration by the DoE under the vendor registration program if the vendor fails to provide
evidence on the arrangements for collecting/recycling batteries and redundant solar systems, or
failure to compliance with this ECOP.

The Implementation Agreement (Legal Agreement) will require the vendors to comply with this
ECOP as a condition of participation of the program. The Grant Manager will monitor
compliance with the ECOP.

The World Bank Team, as part of its supervision mission of the Project, will conduct random
checks on the Project’s compliance to battery disposal and management consistent with the ECOP.
This ECOP may be superseded by national legislation and detailed regulations on the disposal of
batteries, if the requirements of the legislation and regulation meet or exceed the requirements of
this ECOP.

Occupational and Bystander Health and Safety

The systems must be installed by qualified and experienced tradespeople in order to avoid or
minimize electrocution and other health and safety issues such as keeping bystanders away from
work areas, working at height and working with hazardous materials such as batteries.
The project operations manual sets out the minimum requirements for Vendor qualifications and
product standards for work on this Project.

Permission to use land

Most systems will be installed on the landowner or occupier’s property (roof top or pole), and
there will be no land related issues. Micro-grids may need to distribute electricity between
buildings and may cross third party land. Beneficiaries will be required to seek and confirm
permission before works begin.

Specific Requirements under this ECOP

Before working with a battery

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Training in proper handling procedures is very important. Key aspects include:


• Consult battery owners’ manuals for instructions on battery handling and hazard
identification
• Wear personal protective equipment (PPE) such as chemical splash goggles and a face
shield
• Wear acid-resistant equipment such as gauntlet style gloves, an apron, and boots
• Do not tuck pant legs into boots because spilled acid can pool in the bottom of your
boots and burn
• your feet
• Place protective rubber boots on battery cable connections to prevent sparking on
impact if a tool
• does accidentally hit a terminal
• Clean the battery terminals with a plastic brush because wire brushes could create static
and sparks
• Always remove your watches and jewellery before working on a battery. A short-circuit
current can
• weld a ring or strap to metal and cause severe burns
• Cover maintenance tools with several layers of electrical tape to avoid sparking
-
Chemical hazards posed by batteries
Sulfuric acid (electrolyte) in batteries is highly corrosive and acid exposure can lead to skin
irritation, eye damage, respiratory irritation, and tooth enamel erosion. Following the following
principles will assist in managing this risk:

• Never lean over a battery while boosting, testing or charging it


• If acid splashes on your skin or eyes, immediately flood the area with cool running water
for at least 15 minutes and seek medical attention immediately
• Always practice good hygiene and wash your hands after handling a battery and before
eating. If you handle the lead plates in a battery and do not wash your hands properly, you
could be exposed to lead. Signs of lead exposure include mood swings, loss of appetite,
abdominal pain, difficulty sleeping, fatigue, headaches and loss of motor coordination.
• The chemical reaction by-products from a battery include oxygen and hydrogen gas. These
can be explosive at high levels. Overcharging batteries can also create flammable gases.
For this reason, it is very important to store and maintain batteries in a well-ventilated work
area away from all ignition sources and incompatible materials. Cigarettes, flames or
sparks could cause a battery to explode.
• Before working on a battery, disconnect the battery cables. To avoid sparking, always
disconnect the negative battery cable first and reconnect it last. Be careful with flammable
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fluids when working on a battery-powered system. The electrical voltage created by


batteries can ignite flammable materials and cause severe burns. Workers have been injured
and killed when loose or sparking battery connections ignited gasoline and solvent fumes
during system maintenance.

Safe Battery Movement

Lifting and moving batteries needs to be undertaken with care so as to avoid personal and
environmental harm. Key principles include:

• Use proper lifting techniques to avoid back injuries


• Battery casings can be brittle and break easily; they should be handled carefully to
avoid an acid spill
• Make sure that a battery is properly secured and upright in the vehicle or equipment
• If a battery shows signs of damage to the terminals, case or cover, replace it with a new
one

Battery Disposal

For Lead Acid and NiCad batteries, the supplier will ensure that a system is in place to obtain and
properly dispose of these batteries at the time of battery replacement.

Recycling

Lead recycling operations require a high degree of control because of the potential hazards from
air emissions and wastewater discharges.

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Landfill Disposal (Hazardous Waste Facility)

If recycling of batteries is not chosen or possible, disposal in a secure landfill is the next preferred
option. The acid should be removed from the casing and neutralized. Empty battery cases must be
disposed of carefully because they can still contain significant amounts of lead. Batteries should
then be wrapped in heavy duty plastic or encapsulated with concrete. The concrete and plastic
serves the purpose of ensuring that lead will not leach out and become mobile in landfill leachate,
thus reducing the environmental risk.

Capacity-Building and Monitoring of ECOP Implementation

As part of the capacity building to be provided for implementation of the proposed operations, the
vendors and implementing agencies staff will receive training in the ECOP’s application. The
World Bank will monitor and provide guidance in the implementation of the ECOP. Grant
Manager will be responsible, besides other functions, to monitor and supervise the implementation
of the ECOP by Vendors.

Disclosure

This ECOP will be shared with all relevant stakeholders, relevant line departments, concerned
nongovernmental organizations, and development partners. Subsequently, it will be disclosed in
English and Somali language by PIU, and made available on their websites. Copies will also be
held at public buildings, such as libraries and offices of regional authorities, for the rural
communities to access.

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Appendix 1: Information for Battery Awareness Campaign

Introduction

Most homes and businesses contain many pieces of equipment such as portable computers, cell
phones, power tools, standby or backup power systems, cameras, security equipment, radios,
torches, etc. that depend on batteries to operate. As a result, batteries have become integral to the
functioning of our economy and support many aspects of modern lifestyles. These households and
businesses use a number of different types of batteries which have different chemistries.

Non-rechargeable, single-use batteries used in clocks, toys, cameras and remote controls can be
either alkaline and zinc-carbon (AA, AAA, D, C, 9-volt dry cell), mercuric-oxide (button,
cylindrical and rectangular) or lithium (AA, C, button, 9-volt). These batteries are also known as
“primary” or single use batteries because they are normally not recycled and are disposed of after
use.

Rechargeable batteries (also referred to as “secondary” batteries) use lithium-ion (Li-ion), nickel
metal hydride (NiMH) or nickel cadmium (NiCd) chemistry. These are found in such products
high end products as camcorders, mobile phones, laptops and cordless power tools, shavers, and
electric toothbrushes.

Lead-acid batteries are the oldest type of secondary batteries. They are used to supply electrical
power to cars, trucks, tractors, motorcycles, and boats. Small sealed lead-acid batteries are used
for emergency lighting and uninterruptible power supplies.

Used batteries, whether primary or secondary, are potentially hazardous, so they need to be stored
and handled carefully. Some of the materials inside a battery are toxic and may damage skin and
clothes if the battery is damaged or leaking. Used batteries require careful handling to minimize
safety hazard such as explosion and fire and good management to avoid pollution of soil, surface
water and groundwater by storing them under cover and in a bunded area. The three main types of
batteries in common use in solar energy systems are described below

Lithium Batteries

There are two types of lithium batteries in common use: (i) primary (non-rechargeable) metallic
lithium (Li) batteries, which are small in size and have a long life and are used to power toys and
small electronic devices; and (ii) secondary (rechargeable) lithium ion (Li-ion) batteries, which are
one of the lightest rechargeable batteries available and which are found in more expensive products
such as laptops, cameras, mobile phones, power tools and now increasingly in solar powered
devices. Large lithium batteries are found in other applications such as backup power, electric cars
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and some newer air planes. Lithium batteries use lithium in its pure metallic form while Li-ion
batteries use lithium compounds which are much more stable than the elemental lithium used in
lithium batteries.

Both types of lithium batteries can be recycled. During collection, they can be mixed with other
battery types in the collection container as long as certain packaging requirements are met. Larger
lithium batteries (>500g) batteries can be collected but require separate storage from smaller
handheld batteries. The risks associated with lithium battery recycling include the potential for a
fire or explosion if batteries become over-heated from sun or for example, if they short-circuit.

Nickel Cadmium / Nickel-Metal Hydride Batteries

Nickel-Cadmium (NiCd) batteries were the first reasonably priced rechargeable consumer
batteries. They are being superseded by new rechargeables Nickel-Metal Hydride (NiMH)
batteries. Nickel-metal Hydride batteries are related to sealed nickel-cadmium batteries and only
differ from them in that instead of cadmium, hydrogen is used as the active element at the anode.
The energy density of NiMH is more than double that of Lead acid batteries and 40% higher than
that of NiCd. Like NiCd batteries, Nickel-metal Hydride batteries are susceptible to a "memory
effect" although to a lesser extent. They are more expensive than Lead-acid and NiCd batteries,
but they are considered better for the environment.

Lead-Acid Batteries (LAB)

The main components of a lead-acid battery are lead (Pb) electrodes and lead dioxide (PbO2)
electrodes immersed in a solution of water and sulphuric acid. These are generally contained in a
plastic case made from polypropylene. While LAB has a history of reliability, is available
worldwide, and is widely recycled, it is also bulky and heavy, prone to gassing, and sulphation.
The heavy metal element (lead) of the battery makes the battery toxic and improper handling and
disposal of the acid and lead can be hazardous to health and the environment.

Why Recycle?

Batteries pose a risk to human health and the environment if disposed of inappropriately. They
contain heavy metals that are toxic to human health and/or have eco-toxicity impacts if they exceed
certain minimum concentrations in the natural environment. Lead, mercury and cadmium are
particularly toxic, but other metals such as nickel can also be of concern if they leach into surface
or ground water. Batteries also contain valuable metals such as cadmium, lead, zinc, manganese,
cobalt and rare earth metals that can be recovered to minimize the use of natural resources and to

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reduce impacts on the environment which occur in the production, distribution and end-of- life
phases of the battery life-cycle.

Single-use batteries have significant environmental impacts at every stage of their life cycle. The
manufacture of batteries requires use of chemicals to purify metals, extraction of resources by
mining (with potential destruction of wildlife habitat) and production of power by burning fossil
fuels; which in turn contribute to global warming, and creation of air and water pollution. The
importation / transport of batteries requires yet more infrastructure development and energy usage.
In landfills, the chemicals inside batteries can leach from their casings and pollute soil and water
with toxic heavy metals if the batteries are not properly recycled.

The technology for recycling secondary (rechargeable) batteries are well known and widely
deployed in developed and some developing countries. Used LABs are widely collected and
recycled (almost 96% collection in North America). NiCad and Lithium batteries are only now
being recycled. However, in most developing countries, the economics of battery recycling is not
sustainable. The cost of handling batteries (collection, storage, packaging), and transport,
especially in rural areas, far exceed the cost of recycling the batteries. As a result, in most
developing countries, lacking recycling facilities, used batteries are invariably discarded to the
environment. Sometimes used LABs are collected, packaged and exported overseas for recycling,
the economics depending on the price of lead and cost of transportation.

The technology for recycling primary (single use) batteries though available is not widely used,
largely because of cost of recycling and because of battery collection (supply) problems. It is only
now being deployed in North America, Europe and other developed countries.

Although recycling may not be a near term option, batteries – primary and secondary – should be
collected and safely stored for transport to an environmentally safe and secure location for future
processing or to a recycling facility.

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