Mozambique - Organic sugar project of pure diets Mozambique S.A

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ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA)

REPORT SUMMARY

FOR THE

ORGANIC SUGAR PROJECT OF PURE DIETS MOZAMBIQUE S.A.

IN

MOZAMBIQUE

0CTOBER 2015

E&S Team: Erika AUER, Senior Social Development Specialist, ONEC3

Kelello NTOAMPE, Environmental Scientist, ONEC3

Sector Director: K. DIALLO

Regional Director: K. MBEKEANI

Resident Representative: J. RIBEIRO

Division Manager: M. CISSE

AFRICAN DEVELOPMENT BANK GROUP

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) SUMMARY PURELIFE

ORGANIC SUGAR PROJECT

1. INTRODUCTION:

This environmental and social impact assessment summary presents the process, approach, outcomes and

management plan for the Pure Diets Mozambique SA (herein referred as PDMSA) organic sugarcane

cultivation, sugar production and cogeneration (also referred to as ‘cogen’) power plant project proposed at

Malangane, Moamba district Maputo Province in Mozambique. The project is located to the South of the

Inkomati River bank, in Sabie Administrative Post. Moamba is well connected by road and rail. The distance

between Maputo and Moamba is 80 km.

The Pure Life Group is working under the brand “Pure Life” and is operational in several other countries to

shift conventional agriculture practices to organic farming.

Organic farming is a form of agriculture that relies purely on techniques such as green manure, compost, green

harvesting and biological pest control. Organic farming does not uses any chemical, fertilizers or pesticides in

the farming practices. Green manure, bio fertilizers bio pesticides are used in farming that have no adverse

impact on environment or soil fertility. Organic farming is a strategic fundamental choice for the farmer and

PDMSA believes that it is the unique way to ensure a rational and sustainable management of natural

resources.

The Pure Life Group operates as an organic foods supply chain through its 6 major legal entities in 8 countries

with direct access to about 90 boutique corporate consumers / retailers across the world.

As supply chain managers, the Group is involved in the entire farm to fork spectrum from soil preparation to

final dispatch of goods to the end customer. It has a team of technical experts handling each level of the supply

chain; market analysis, product development, research and development, soil preparation, farming, farmer

dialogue and training, production, quality check, food safety, warehousing, dispatch, logistics and distribution.

The Group also collaborates with local agricultural universities in the countries where it has operations to

provide technical support to the farmers. It works with over 22000 farmers and over 79000 ha of farmland,

some of which are under various organic food certification process. As well as one affiliate organic mill also

in India, which is the source of its organic sugar supplies. Pure Life Group also works with farmer groups and

has organic food and feed projects in Vietnam, Mozambique and Latin America (in LatAm projects are at

nascent stage.) It ensures production and supply of organic produce, including sugar, by deeply involving

itself at the grass root level. The company through its team of technical experts in these countries engages in

closely monitoring the produce right from soil preparation and overseeing the farm practices to critically

observing and evaluating every step of the production processing.

Its project development team identifies local farmers willing to learn and convert to organic farming. Through

continuous education and training sessions, Pure Life helps farmers take on organic and Fairtrade practices.

Its experts interact with farmers, test soil and seedlings, monitor farming practice, record relevant data required

for inspections and audits by organic certification bodies, and ensures compliance with the standards. It has

Field Officers trained in imparting knowledge of organic farming.

These experts work with farmers to help them develop farmland and farming activities and practice which

meet organic requirements. Pure Life staff organizes regular trainings at its project sites to ensure that the

farmers are constantly in touch with the latest standards to be followed. It also provides financial support

through distribution of free organic agricultural inputs. The Group has a certification team at its New Delhi

office, which works with projects and farmers across India and elsewhere. The Group’s production team

regularly monitors the production from the perspective of all the standards like food safety, quality assurance,

HACCP, GMP, social and environmental aspects, OSH etc. It ensures that all units have food safety

certifications such as ISO 22000, HACCP, Kosher, and Halal if required.

The Group also has track record working with demanding and varied certification agencies worldwide such

as OneCert, USDA Organic, FDA, Fair Trade, Control Union and EcoCert. The company has in the past

worked with farmers who own their own land, but the company is are closely involved in monitoring farm

production and processing activities. It is this wealth of experience working with local farmers and global

organic standards which the Group’s management brings to PDMSA. The following table provide a brief

overview of Pure Life operations worldwide. The below acreage is totally owned by the farmers, which the

Group works with and trains to promote organic farming. Pure Life Group Projects Overview (Organic Crop Production)

Name of Country No. of Projects No of registered farmers Reg. area (ha)

Tanzania 7 10047 55205.455

Vietnam 7 1361 3575.97

Mozambique 2 2329 8274.35

India 30 8449 12248.717

GRAND TOTAL 46 22186 79304.492

Pure Life Group Projects Overview (Sugar Processing)

Name of Country No. of Projects

Vietnam 5

India 3

https://en.wikipedia.org/wiki/Agriculture

https://en.wikipedia.org/wiki/Green_manure

https://en.wikipedia.org/wiki/Compost

https://en.wikipedia.org/wiki/Biological_pest_control

PDMSA has proposed to set up new sugar mill of 3500 tonnes of cane per day (TCD) expandable to a 5000

TCD capacity along with a 12 megawatt (MW) capacity co-generation power project for captive consumption.

PDMSA has also proposed to cultivate 4311hectares (ha) of land for organic sugarcane in a phased manner.

An additional 650 ha of land shall be used for setting up necessary infrastructure like factory, roads, housing,

and reservoirs. Out of this 650 ha, 200 ha is reserved for the factory. The power generated by the cogeneration

plant will be utilized for its own consumption and irrigation facilities.

2. PROJECT DESCRIPTION AND JUSTIFICATION:

2.1 Description:

PDMSA proposes to implement the organic sugar production 0.45 to 0.9 million metric tonnes (MMT) of cane

per year and a sugar mill of 3500 TCD capacity expandable to 5000 TCD for 240 days. In addition, PDMSA

will establish a captive cogeneration power plant by end of year 2017. The project will produce sustainable

and organic sugarcane and intends to use innovative agriculture practices to support and enhance soil fertility

while simultaneously fixing organic matter and carbon in the soil and reduce the environmental and social

impacts of the production. Land clearing will be by mechanical methods. Land clearing and preparation will

employ procedures to minimize release of greenhouse gases (GHGs). Cleared biomass will not be burnt but

chipped and ploughed into the soil during land preparation stage or used to produce compost. Larger biomass

will be brought to the plant site and stored for use for producing power during operations.

Irrigation systems will be installed, followed by the planting of the first commercial crop. A variety of

irrigation systems will be used including centre pivots, semi-solid sprinkler and sub-surface drip systems in

order to optimise agricultural yield and ensure efficient water management for the specific soil. The water

rights are issued to all water users based on the water availability and the command area under consideration

by the regional water authority Administração Regional de Águas – South (ARAsul). ARAsul will inspect

and monitor all the water users in the area every month based on the area under irrigation. PDMSA’s irrigation

engineer will monitor the abstraction to ensure compliance with ARAsul requirements. The project will use

water from the Corumana dam, which has water storage capacity is 881 million cubic meters without gates.

The Mozambique government has provided the approval for installation of gates at the dam during 2016 to

2018 to further increase its storage capacity. After installation of gates the estimated storage capacity of the

dam would be 1240 million cubic meters. The command area of the dam for irrigation is 33,000 hectares.

Water rights have been given to various stakeholders for irrigation up to 23,000 ha including PDMSA’s 4311

ha. PDMSA has water rights for 43.11 million cubic meters/ annum. ARAsul authorities have confirmed that

this quantity of water that can be sustainably abstracted and will not have any adverse effect on the water

resources in the area. PDMSA currently has a permit for water usuage, but a more permanent water concession

is being discussed with the government to be provided by July 2016; this permit will be valid for 50 years.

The Mozambique Government has also commenced the construction of Moamba Major dam which is

expected to be completed in 5 years with the same capacity as that of Corumana dam. This would be

advantageous for the project as it will supply water to Maputo city, thereby freeing up water from the

Corumana dam for agricultural and industrial users downstream. The project site located nearer to both the

dams, and hence it has got high assurance of water supplies.

Planting and harvesting of sugar cane will be done using mechanical planters and equipment respectively. In-

field tractor-trailer combination will transport cut sugar cane. Since the sugar content is highest at the base,

cane will be cut as close as possible to the ground. The remaining cut will be the base for new cane growth

(ratoons) in the following season. The crop is typically replanted after 6 to 8 ratoons. During the replanting

phase, minimum tillage techniques will be implemented to minimise the release of GHGs. The replanting

schedule will also allow for a fallow crop.

Mechanical harvesting of the cane will leave a blanket of trash leaves and tops in the fields that gradually

build up the organic matter and carbon content of the soils which, in addition to being a carbon sink, improves

the quality of the soils as well as minimise the growth of weeds.

2.1.1 Sugar Plant Operations Following harvesting, the cut sugar cane is transported within 24 hours to the facility to avoid deterioration of

sugar content. Upon receiving at the processing plant, the sugar cane is mechanically shredded, run through a

diffuser to extract the juice, and separated from the residual fibres (bagasse). The juice is then put through a

clarification and evaporation process. The facility will be designed to be flexible so that some juice can be

sent not only for sugar production but also for production.

The processing plant will be in full operation for eight to nine months, approximately June through February

(approximately 240 effective days per year). During this relatively dry period sugar cane is harvested and

sugar and power shall be produced. Non-operational time shall be used for maintenance of the plant.

Production may be extended to later in the rainy season by storing molasses or by purchasing molasses from

at other estates.

2.1.2 Power Generation The bagasse will be fed into a high pressure boiler to generate steam and electricity. The steam and electricity

shall be used to fully supply the industrial plant and the irrigation system with renewable energy. The facility

is designed for efficient and minimum internal use of steam and power in order to maximise the surplus

electricity that can be sold to the national power grid. The boiler is designed to also be able to utilise secondary

biomass such as wood chips and energy grass as fuel. The boiler flue gas treatment will consist of a filter

system to minimise emissions of harmful compounds. Power will be generated for use during the full year

with exception for a number of weeks required for maintenance of the boiler.

2.1.3 Effluent & Air Pollutant Treatment Facility Effluent waste stream from the industrial plant has got a high chemical oxygen demand and biochemical

oxygen demand makes it a potential hazard to the environment. However, effluent also has high nutrient

value. The effluent and the sewage shall be treated and the high quality recycled water used for landscaping.

Electrostatic precipitation and wet scrubber will be used to treat other polluting gases generated from project

operations.

2.1.4 Utilities & Consumables

Water and power are the main utilities required for operating the integrated project. Water will be drawn from

the Inkomati River flowing on the border of proposed site. Power required for construction and in case of shut

down of plant, will be drawn from the local grid.

2.2 Justification for the Site

The proposed site is ideal for the proposed integrated sugar & cogen power project, due to following reasons:

Required land for cane development is available at the project site on lease for PDMSA.

The site is easily accessible by road, and near to Maputo Port and Maputo International Airport.

The command area has huge potential for the sugar cane because of the huge irrigation potential.

The site is near to the Inkomati River which is flowing close to proposed factory premises.

3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

The ESIA for the project was carried out under the following Policy, Legal and Administrative Framework:

o The constitution of the Republic of Mozambique in its Article 72 states that "every citizen shall have the

right to live in a balanced environment and the duty to defend" and in Article37 "The State shall promote

efforts to guarantee the ecological balance and the conservation and Preservation of the environment in

order to improve the citizen's quality of life.

o The National Environment Policy (approved by resolution 5/95 of 06 December 1995) reinforced the

reasoning of other environmental legislation. The main objective of the policy is to provide a tool to ensure

that sustainable development can occur, and to allow the use of natural resources in a way that preserves

its operation for future generations.

o The Environmental Law (Law No. 20/97 of 07 October 1997) applies to public and private sectors and

sets the legal basis for the sound use of natural resources in a way that improves the quality of life of

citizens, prioritizes the development of techniques that minimize environmental degradation, emphasizes

public participation, and integrates principles of payment of polluters.

o The legislation of Environmental Impact Assessment (EIA), approved by Decree 45/2004 of 29 September

2004, is applied to all activities of public and private sector. The legislation employs three categories of

environment assessment:

- Category A: is for projects that could potentially have significant impacts due to the nature of the

activity and or environmental sensitivity hosting the project. You are prompted a full EIA.

- Category B: is for projects that would have negative impacts but the extent, intensity and duration are

less, and the impacts can be largely mitigated. It asked for a Simplified Environmental Study.

- Category C: is for projects that have minimal impacts and the completion of an Environmental Impact

Assessment are not required.

3.1 Other pieces of legislation and requirements includes:

Prohibition of grasping of marine foliage of Euchema gender by Portaria (Ministerial Legal

Instrument) no. 23651 of 12 December 1970

Regulation of Port Captainship, approved by Portaria (Ministerial Legal Instrument) n. 1097, of March

20th, 1967

Regulation Relating to the Process of Environmental Auditing, approved by Decree n. 32/2003, of

August 20th

Regulation on Bio-medical Waste Management, approved by Decree n. 8/2004, of February 18th)

Regulation on Environment Quality Standards approved by Decree n. 18/2004 of June 2nd

Environmental Regulation on Mining Activity, approved by Decree n. 26/2004, of August 20th vii)

Regulation on the Process of Environmental Impact Assessment, approved by Decree n. 45/2004, of

September 29th, revokes Decree n. 76/98, of December 29th

Norms of application of fines and other sanctions provided for in environmental legislation, approved

by Ministerial Diploma n. 1/2006

General Waste Management Regulation, approved by Decree n. 13/2006, of June 15th

General Regulation on Marine Fisheries (REPMAR), Decree n. 43/2003, of December 10th

General Aquaculture Regulation, Decree n. 35/2001, of November 13th

Environmental Inspection Regulation, approved by Decree n. 11/2006, of June 15th

Forests and Wildlife Regulation, approved by Decree n. of June 22nd

Land Use Regulation, approved by Decree n. 66/98, of December 8th

Regulation for Industrial Activities Licensing, Decree n. 39/2003, of November 26th

Article 109 – land, Article 110- Enjoyment of Land and Article 111- Rights Acquired Through

Inheritance or Occupation of Land of the constitution of Mozambique

3.2 AfDB Requirements:

The following Operational Safeguards standards have been triggered:

OS1: an Environmental and Social Assessment will have to be carried out in order to determine the

extent of the environmental and social impacts of the project;

OS2: the project and associated project will require involuntary resettlement.

OS3: it is expected that the project will impact the ecosystem service on which the local population

depend in in terms of sustenance, livelihood and/or primary income.

OS4: it is expected that the project will cause adverse environmental and social impact owing to

emission of pollutants and waste or hazardous materials.

OS 5: the project involves the establishment of workforce.

3.3 Relevant International Treaties and Conventions include:

Dates Relevant International and Regional Conventions; 1982

United Nations Convention on the Law of the Sea (UNCLOS) 1992

United Nations Framework Convention on Biological Diversity (CBD) 1973/78

International Convention for the Prevention of Pollution by Ships (MARPOL) 1998

Convention on Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in

International Trade (PIC) 2001

Convention on Persistent Organic Pollutants (POPs) 1972 Convention on the Prevention of Marine

Pollution by Dumping of Wastes and Other Matter (The London Convention) 1997

Convention on the Non Navigational Uses of International Watercourses (Watercourses) 1985 Nairobi

Convention for the Protection, Management and Development of the Marine and Coastal Environment

of the Eastern Africa Region and Its two protocols on SPAW and Emergency in Cases of Oil spills)

1968/2003

African Convention on the Conservation of Nature and Natural Resources(Algiers, Maputo) 1992 UN

Framework Convention on Climate Change (UNFCCC) 1994

UN Convention to Combat Desertification (UNCCD) 1989

Convention on the Control of Trans boundary Movements of Hazardous Wastes and Their Disposal

(Basel) 1991

Convention on the Ban of the Import into Africa and the Control of Trans boundary Movement and

Management of Hazardous Wastes within Africa (Bamako).

Millennium Development Goals

4. DESCRIPTION OF PROJECT ENVIRONMENT

4.1 Latitude & Longitude

The area lies between 25 degree, 20’, and 25 degree 30’, south latitudes and between 32 degree 10’, and 32

degree 30’, east longitudes.

4.2 Rainfall

The months of June, July, August and September are receiving the lowest rain fall in the year and January to

March seems to be highest rainfall receiving months. The rainfall details of the last ten years shows the average

rainfall per year is 603 mm. It is noticed that 2003, 2004, 2005, 2006, 2007 & 2008 received below normal

rainfall while the balance years in the last decade like 2002, 2009, 2010 & 2011 have received above normal

rainfall.

4.3 Temperature & Humidity

January to March high temperature levels of about 310C and July to September have low temperatures of about

130C. The wider difference between the day and night temperature is recorded at over 150C during the months

June to September is giving the highly favourable diurnal variation for the best sugar accumulation in the

sugarcane stalks.

4.4 Evaporation

The average evaporation for the last 10 years is about 1505 mm due to less rainfall and high temperature.

4.5 Relative Humidity

The Relative humidity is seems to be an advantageous factor as the crop can withstand some prolonged

drought with the available irrigation systems. The average relative humidity is 65% in the project area.

4.6 Sunshine hours

On average, there is over 8 hours sunshine in Moamba which will facilitate sugarcane crop with better sugar

accumulation and sugarcane yield.

4.7 Land Use:

Moamba is well connected by road and rail. The distance between Maputo and Moamba is 60 km. An

estimated potential arable land of 229,000 ha in the district of Moamba, with land use pattern as follows:

Area occupied by corporate farms are 33,600 ha (24,500 ha of rain fed and irrigated 9,100 ha)

13000 ha are occupied by family farms with an average holding size of 1.3 ha.

Total area occupied by corporate and family farms are 43,600ha which is 20.3% of total arable land in

Moamba District.

60,000 ha area occupied as pasture for livestock which is 26.2 % of arable land.

Hence balance of 125,400 ha (53.5%) is the potential area available for further development.

The main crops grown for food by most of the population are Maize, cassava, cow peas followed by

sweet potato pea nuts, pumpkins along with vegetables.

4.8 Noise & Air Quality

4.8.1 Daytime Noise Effects

During the daytime (0700 to 2200, total Project noise from operations at the factory site ,plus baseline levels

is predicted to be well below the IFC daytime LAeq standard of 55 dBA at the closest receptor, Malengane

Village. The highest daytime LAeq level (including baseline levels) predicted at Malengane Village (6 km

from factory site), is 27 dBA, which is 28.1 dBA below the IFC daytime noise guideline. Based on the

information above, no exceedances of the daytime IFC guidelines are projected for any of the nearby receptors

within the Study Area (Malengane Village). Therefore, the noise effect of the Malengane Project during the

daytime will be insignificant (low severity; low likelihood). No specific mitigation measures are required

during daytime operations.

4.8.2 Night-time Noise Effects

During the night-time (2200 to 0700), noise from operations at the factory site, plus baseline levels is predicted

to be well below the IFC LAeq standard of 45 dBA at the closest receptor, Malengane Village The highest

night-time LAeq level (including baseline levels) predicted at Malengane Village (6 km from the factory site),

is 26.9 dBA, which is 28.1 dBA below the IFC daytime noise guideline. Based on the information above, no

exceedances of the night-time IFC guidelines are projected for any of the nearby receptors within the Study

Area (Malengane Village). Therefore, the noise effect of the Malengane Project during the night-time will be

insignificant (low severity; low likelihood). No specific mitigation measures are required during night- time

operations.

4.8.3 Transportation Noise Effects

During the operations phase, movement of trucks (i.e., transport of sugarcane and raw sugar) along the

Transport Corridor will result in increased noise levels at nearby receptors along the corridor. Based on

observations there are no receptor within 100 m of the factory. Along the corridor (just based on observation;

no traffic counts or baseline noise levels were taken along the Transport Corridor). The increase in Project-

related truck traffic is expected to increase noise levels along the corridor and as such, result in a moderate

noise impact (low severity; high likelihood). Recommended mitigation measures to control the noise

emissions are listed below.

4.8.4 One of the main sources of air emissions at the project site and which could potentially generate

significant amounts of carbon monoxide (CO) and dust is the burning of open fields which is done as hunting

strategy and also the production of charcoal for domestic use is very common.

4.9 Geology / Geomorphology & Soils

The project is located in ancient alluvial terraces of the Inkomati River with altitudes ranging between 60 and

85 meters. In this region there is basaltic soils or alluvial terraces in the wide of the Inkomati River floodplain,

with a surface layer of organic matter, with a fertility level from medium to high and with a good agricultural

potential. The shape, thickness, and the nature of the layers vary according to the extent and strength of the

floods that gave rise to the sedimentation process. Most of the proposed area is dominated by alluvial soil and

clay being characterized by, deep, well drained with a bulk density of 1.1 to 1.4 g / cm3, total porosity, with

groundwater above 4 to 6 feet deep, with a water retention capacity of 12 to 16%. The pH is between 5.7 &

7.1

4.10 Flora

Typical vegetation of this region is the savanna and thickets of thorny Acacia spp, and species that accumulate

water reserves in the leaves (Euphorbia spp) .These typically occur in shallow soils, reddish, sandy clay. The

occurrence of dense forest is limited to a spot the terrain east, with the notable presence of the Euphorbia

genus. In sandy and shallow soils, the dominance of Acacia genus species are typical in open woods and

alternate with spots with dominance Cobretum spp, occasionally mixed with Terminalia sericea. Associated

woody species include Dichrostachys cinerea, Grewia sp. Euclea natalensis, and African Spyrostachys and

Sclerocarya birrea. The area is covered with grasses as a result of the conversion by human activity, with the

removal of woody component to obtain fuelwood and to open fields for farming and grazing. Much of the

area to be occupied at present for the cultivation of cane sugar had its natural vegetation removed during

colonial times and was converted to grazing areas

4.11 Fauna

In the middle of terrestrial vegetation, it is normal to experience insects, including beetles, mantis, dragonflies,

butterflies, moths, flies, ants, bees, wasps, as well as a variety of scorpions and spiders. Larger animals

currently exist, only rats and snakes. Due to the proximity of the Inkomati River, in the north land area, we

found the presence of gallery forest along their banks constituted by Acacia xanthophloea and Ficus Capri

folia showing up sometimes reclinata Phoenix palm tree and the reed Phragmitis communist. Large mammals

have not been spotted at the project site but next to the River Inkomati, mammalian species associated with

riparian habitats have been observed. These include water ichneumon (Atilax paludinosus), the otter (Aonix

capensis) and the mouse sugarcane (Thryonomys swuinderanus). In the very bed of the Inkomati River or on

its banks the lizard Nile (Varanus niloticus) and the Nile crocodile (Crocodile niloticus) were observed and

nest on the river bank.

In terms of fish fauna, according to Jubb (1967) and Skelton (2001), River Inkomati there is about 50 species

of fish. Most of these fish species make seasonal migrations to side tributaries, wetlands, and floodplains for

breeding. On the other hand, Anguilla marmorata, Anguilla bengalensis labiata, Anguilla, Mozambican and

Anguilla bicolor which go to the sea for reproduction purposes also occur.

4.12 Hydrology

Moamba and the area where it is to implement the draft organic production of cane sugar, is located about a

hundred meters from the Inkomati the bed, which is the main supplier of water. This Inkomati River rises to

about 2000 m altitude in the plateau and mountainous area west of the basin. The Inkomati River Basin has

an area of 46,700 square kilometers and is shared by South Africa, Swaziland and Mozambique. About 33.4%

of the basin lies in Mozambique and is below 200 m elevation, essentially a flood plain lying east of the

Lebombo mountain range. The main tributaries of this river are the Komati, the Crocodile and the Sabie. 80%

of the total flow, occurs between the months of November and March.

4.13 Baseline details about Socio Economic status

In 2007 the District of Moamba, had 56,559 inhabitants. The projections of the National Institute of Statistics,

estimate a population of 68,231 individuals in 2015. A population with a sex ratio of 93 means that the

population is affected by male emigration movement. Reasons include close proximity to the border with

South African Republic and Swaziland. Moreover, there are no employment opportunities.

4.14 Education Levels

51% people of 5 years or more (predominantly men) attend or have already attended primary school. The

highest range of access to schools have been noted in the age group of 10 to 14 years (64%) and being followed

by the age group of 5 to 9 years. This reflects that majority of the rural children take late entry to the school.

The majority of these children who attend primary education are boys. This is primarily due to the inadequate

or non-existent school network teachers in the district.

4.15 Housing, Electricity and Sanitation

The district of Moamba has 10,602 houses out of which around 80% are made from straw or other locally

available material. ~12% are apartments or constructed houses and ~8 % are made from Zinc and wood. ~22%

of the household have municipal water connection and ~57% of the population has access to sanitation

facilities. However, good quality facility is consolidated only in the areas where people have apartments or

house. The population in the proposed project area has got very limited sanitation facilities.

Power is on the national EDM power distribution system which is present in the town of Moamba. The

direction of the current project is in coordination with the EDM and has already made the extension of the

power grid to the project area. The availability of electricity is a major problem in the area with only 13% of

the total population having access to regular supply of electricity. Around 41% of the population has access

to radio and the number is expected to increase drastically due rapid increase in utilization of mobile phones

in the area.

4.16 Drinking Water Availability

With regards to the sources of supply of water, 40% of the people use water directly from rivers or lakes and

27% from the well or holes. Most of the available existing water supply schemes have quality problems. As a

result, many people who use unclean sources suffer from water borne diseases.

4.17 Livelihoods

Most of the people practice rudimentary subsistence agriculture, rearing goats and chickens. Some families

have small stalls and trade various commodities. Some people are involved in in logging, selling firewood or

producing charcoal.

4.18 Conflict Resolution Process

The conflicts within the community are generally resolved within the purview of law. In case of any conflict

within the community the following are approached in the following order:

- Village Authority (Approved by Government)

- Local Authority

- Forum of Local Leaders (Approved by Communities)

- Administrative Level

- Provincial Levels

- National Level

4.19 Health Facilities, HIV and Vector Diseases

Most illnesses are communicable, directly or indirectly, and are related to lack of adequate and safe drinking

water supplies and sanitation, low living standards and poor nutrition. Waterborne and vector borne diseases

are also prevalent in the area. The prevalent diseases in the project area include malaria, intestinal parasites,

diarrhoea, etc. Most of these diseases are not only causes of illness and suffering but also hospitalization.

Malaria has the most victims followed by diseases such as HIV/AIDS, diarrhoea, measles, pneumonia, TB

and typhoid. Malnutrition is prevalent and observable, especially, among the people in the age group of 5-10

years. More services for the prevention, control and cure of infectious diseases, particularly vector-borne ones,

are required. Based on preliminary field assessment, it has been possible to identify the following problems

associated with health service system:

- Health institutions are limited and hardly ever located in rural areas.

- Lack of qualified health staff

- Inadequate supply of drugs and equipment

- Budgetary constraints

4.20 Cultural Resources

The project surroundings have been investigated in terms of religious and cultural site and archaeological

importance. There are no World Heritage listed sites or recorded archaeological sites in the project area.

Tsonga language (Tsonga) and Portuguese are the main languages in this region. The main ethnic group is

Tsonga and a wide range of religious groups exist in the study area with significant proportion of followers.

Major religions practiced in the project area are Christianity (67.6%) and traditional religions (22.9%).

5. PROJECT ALTERNATIVES

5.1 The assessment of alternatives considered alternative in five categories:

Demand alternatives (e.g. producing only rather than developing the proposed project area for edible

sugar production, applying less developed power generation concepts, which generate significantly

less power to the local grid, locating the project site to a different area in the district, region or nation);

Process alternatives (e.g. re-use of waste material, the use of other technologies);

Schedule alternatives (e.g. restricting construction or operations to a certain time of year).

Input alternatives (e.g. use of other raw materials)

Scale alternatives (e.g. changing the scale of the proposed development in order to comply with

environmental and social requirements).

5.2 A range of systematic methods was used to compare and evaluate the various alternatives including

checklists, overlay maps, matrices etc. The following economic, environmental and social aspects were

considered while selecting this site:

- The site is located in upland area with excellent gravitation drainage system (indicated in water

management plan) and hence there is absolutely no risk of flooding and damage to the crop. It was

observed that the other sugar plantation located in low land areas have the risk of flood and crop

damage and hence incurring the economic loss.

- The land in this project area is not used for doing any agricultural activity and as per government

records it’s a bushy land. Hence redeveloping the land for sugarcane plantation will not result into any

loss of agricultural income.

- There is sufficient availability of water for irrigation (as indicated by ARAsul post consultation with

downstream users and regular monitoring of water levels) and hence scarcity of water for irrigation

purpose is not envisaged.

- Due to the upcoming Moamba Dam the water security will be even more strengthened.

- The area is scarcely populated hence there will be negligible disruption with the population habitat.

- There are no world heritage sites, archaeological sites and sacred sites within the project area and

hence no loss to the cultural heritage is envisaged.

- The community in the vicinity of the site have very limited socio economic resources, the project

would make positive impacts on their lives in terms of employment, Medical facilities, education,

sanitation and drinking water facilities etc.

- The access roads to this area are either not available or damaged, the project would help in developing

access roads thereby improvising economic activities and increasing income generation operations.

- A railway line is proposed to be developed on the eastern side of the project area thereby providing

logistic support to the project.

- Maputo International Airport and Port are just 90kms away thereby providing the logistic support and

enhanced economic mobility.

- Availability of sufficient local workforce to cater the needs of plantation activities, project would

generate sufficient employment in the area.

- The soil conditions and climate is highly conducive for sugarcane plantation.

5.3 No Project Alternative

If the project is not undertaken and if the currently land use were to continue the remaining pockets of valuable

biodiversity currently in the area would in all likelihood be decimated by the rapidly increasing unsustainable

charcoal making, releasing comparatively great amounts of carbon to the atmosphere. The project’s public

benefits such as increased revenue to the government, improved infrastructure, introduction of a new cash

crop and thousands of employment opportunities would not be realised. The No Project Alternative would

also aggravate the poor socio economic conditions of the community.

5.4 Site Alternatives

The project is the one of the largest organic sugar project taken up in a planned manner in Mozambique. The

project site was selected due to proximity to Maputo Airport and Maputo Port, access to infrastructure, land

ownership structure and the existence of surrounding villages that are willing to participate in the project.

After discussions with Government of Mozambique and other relevant stakeholders the company was advised

to develop this project in Malangane.

5.5 Technology Alternatives

The technology of the operation of a large-scale sugar cane plantation is well established in Mozambique.

However the technology of utilising modern irrigation systems and processing sugar cane into sugar and power

is well established in neighbouring South Africa, Brazil and India where the process technology providers are

coming from. Therefore, the risk of uncertainty in functionality from establishing the chosen technologies is

minimal.

6. POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS

6.1 Summary of Negative Impacts Construction Phase

- Change in population level due to influx of workers and labourers causing pressure to social services,

food and facilities

- Soil erosion due to runoff effects and loosened top soil during ploughing and planting

- Changes in the quality of surface water due to various pollutants

- Changes in the level of crime due to increased number of people in the area

- Increase in the risk of communicable diseases (e.g. HIV/AIDS) and human health due to increased

population of workers and social interactions

- Change in the level of traffic intensity and traffic accidents due to increased number of vehicles

concurrently with better transport facilities

- Loss in the village workforce to the project

- Loss of biodiversity during clearing and establishment of the plantation

- Fair compensation for land and other properties to be affected by the project

6.2 Summary of Negative Impacts Operational Phase

- Localised changes in surface and groundwater hydrology due to the project activities notably

irrigation.

- Changes in the quality of surface and groundwater due to waste and other pollutants

- Potential interference with migration routes of animals

- Increase in the level of crime due to increase in population in the area

- Interference with aquatic ecology

- Increase in the risk of communicable diseases and human health due to increased population of workers

and social interactions

- Increase in population due to influx of workers and labourers increasing pressure to social services,

food and facilities

- Increase in the volume of traffic intensity and traffic accidents due to project activities concurrently

with better transport facilities.

- Increase in income in the village will lead to youth resorting to prostitution, drinking and loss of

morality

- Increased resource use conflicts, particularly land and water

- Loss in the village workforce to the project.

- Loss of access to the natural resources found at the barren project area e.g. for grazing, hunting

(poaching) and charcoal making

- Gas emissions

6.3 Summary of Negative Impact Decommissioning Phase

- Soil erosion due to run off effects and loosened top soil due the removal of sugar cane

- Loss of employment and income to workers, local economy and the nation

- Change in life style and quality of workers due to loss of employment

6.4 Summary of Positive Impacts of Project

- Employment generation for the Community

- Economic development of the community

- Community will get access to better education facility

- Community will get access to medical facility

- Community will get access to safe drinking water

- Community will get access to better housing, sanitation facility

- Community will get access to public infrastructure

- Community will get financial inclusion through ATMs and Bank Branch

7. MITIGATION:

7.1 Climate and Air Quality

Dust suppression as needed, i.e., watering disturbed areas during dry and windy conditions;

Use of new bagasse and trash-fired Cogeneration Plant with high energy efficiency boilers;

Regular maintenance of the boilers and all equipment;

Installation of emission reduction systems, such as wet scrubbers or electrostatic precipitator (ESP)

technology, on the boilers.

Climate Risk Assessment and Development of Adaption Plan.

7.2 Greenhouse Gases

Ensure densification of vegetation on fringes of cultivated lands

Location of factory at the center of the Project Area to minimize traveling distance for trucks transporting

cane to factory and ultimately minimizing diesel consumption;

Use of bagasse (90 percent) and non-hazardous waste (9 percent) as fuel for the Cogeneration power plant

boilers to produce onsite power and heat requirements (renewable fuel);

Transport of concentrated vinasse to cane field for reuse as fertilizer;

Facilitate the planting of trees and other afforestation to offset loss associated with cleared areas;

Ensure use of well maintained, high efficiency diesel motors for the portable irrigation pumps and mobile

drainage pumps;

Ensure use of energy efficient lighting, heating, and ventilation at factory site;

Where feasible, practice no till and/or minimum till at planting;

Ensure maximum efficiency of tractor passes per hectare during cultivation and crop maintenance;

Ensure precision application of synthetic nitrogen;

Ensure maximum energy efficiency of the conversion process ( and raw sugar production); and

Ensure adequate maintenance of all transport vehicles.

7.3 Noise

Regular maintenance of all trucks in accordance with manufacturer’s specifications;

Install sound suppressive devices (such as mufflers) on the trucks;

Educate truck drivers and ensure they do not exceed a speed limit of 50 km along densely populated areas

along the corridor.

Deployment of acoustic chambers wherever necessary

7.4 Geology, Topography, and Soils

Implement soil erosion, storm water runoff, and sediment control measures, including the use of

appropriate best management practices during clearance activities.

include clearing only small tracks of land at one time and minimizing the length of time that the cleared

areas for industrial use are void of vegetation or for agriculture use not under active cultivation;

Schedule the majority of the construction and land preparation activities, to the extent practicable, to occur

in the dry season and when land has been appropriately drained, or by limiting off-road access, and by

implementing an awareness education and training program;

Use of improved equipment, such as chain drags between bulldozers and the use of root rakes, floating

blades, and careful/knowledgeable equipment operators;

Spill control will be exercised by inspecting equipment, hiring trained and dedicated feelers and

implementing a Spill Prevention and Countermeasures Plan (SPCC). The SPCC Plan describes measures

to be implemented by PDMSA and its contractors to prevent, and if necessary, contain and control

inadvertent spill of hazardous material such as fuels, lubricants, and chemicals, containment walls, and

other measures. In addition, a training module will be developed to educate employees on the SPCC Plan.

7.5 Biological Resources

7.5.1 Terrestrial Biological Resources

The following measures are recommended to mitigate potential biological resources impacts:

Rehabilitation of the Project Area once the Project is concluded;

Include a 50-90 meter wide buffer area Inkomati River to preserves a band of natural, seasonally

flooded habitat within the most species rich and diverse habitats;

Containment of oil, fuel, and chemicals with bunds or similar devices;

A Spill Management Plan will be developed and implemented, which will contain specific measures for

safe handling and storage of hazardous materials;

Enforcement of speed limits on roads to minimize vehicular collisions with wildlife and driver education

trainings to reduce wildlife injury and mortality;

Worker education on the species of concern in the area and how to avoid impacting them; and

Maintain corridors to allow for movement of large mammals.

7.5.2 Aquatic Biological Resources

Creation of a 50-90 meter wide buffer zone along Inkomati River that preserves a band of natural, seasonally

flooded habitat for the aquatic fauna

7.6 Social Economical & Cultural Resources

Completion of archaeological field surveys in previously undisturbed portions of the Project site;

Establishing a Chance/accidental Find Program and training for Project managers and workers; and

Maintaining flexibility in final Project design to protect any unanticipated finds.

8. MONITORING PLAN

SL#

Action Plan Budget

in USD

Timeline/

Frequency

1 Purchase of High Volume Air Sampler for Air Quality (PM10, NOx, SOx, CO),

Noise ,Water Quality and Soil Quality Monitoring Equipment for carrying out

monthly in-house monitoring

15000 Jan 2015

2 In house Air Quality & Noise Level Monitoring 50000 Fortnightly

3 In house Effluent Quality Monitoring 80000 Weekly

SL#

Action Plan Budget

in USD

Timeline/

Frequency

4 Annual Monitoring of the Air Quality, Water Quality, Noise Levels and Soil

Quality parameters by third party laboratory

30000 Annually

5 Conducting Workshop- Worker Health & Safety Management 50000 Quarterly

6 Purchase of Applicable Personnel Protective Equipment for In-house Staff 75000 Annually

7 Purchase of Fire Fighting Equipment’s for Project office- Class A B C as

applicable

20000 Annually

8 Comprehensive Capacity Building Program for 2 Safety Engineers 10000 Mar 2016

9 Appointment of dedicated HSE Manager 90000 Jan 2016

10 Health and Safety Training of EPC Contractor 80000 Quarterly

11 Development and Implementation of ISO 14001:2004 and OHSAS18001:2007

Management System -For Pure Diets Mozambique SA

30000 Feb 2016

12 Developing and Implementing EPC Contractor HSE & Social Guidelines for

Man, Material or Machinery Contract

15000 Dec 2015

13 EPC Contractor Monitoring - health Safety Environment & Social Compliance -

Annual Reporting by Third Party

60000 Annually

14 Developing and Implementing Social Accountability SA8000:2008 Management

System

17000 Mar 2016

15 Developing GHG Accounting System Framework as per WRI

Guidelines/ISO14064 SCOPE 1 & SCOPE 2

55000 Aug 2016

16 Developing and Implementing Global Reporting Initiative Framework GRI 4- to

Report Pure Deits Annual Performance of Sustainability, Environmental &

Social Issues to ALL THE LENDERS & Stakeholders

105000 Annually

17 Conducting HIV/AIDS & vector Diseases Awareness Program for Community 20000 Quarterly

18 Conducting Community Perception Survey on E&S, Economic Aspects 50000 Annually

19 Independent E&S audit- annual basis as suggested by lender group 80000 Annually

20 Climate Adaptation studies 50000 Oct 2016

21 Surface and Ground water Hydrology Modelling 40000 Dec 2016

22 Implementation and Training of the E&S management plans (Already

Developed):

- Construction Environmental Management ;

- Worker Health and Safety Management;

- Biodiversity Management;

- Catchment Management;

- Waste Management, Reuse and Recycle;

- Worker Health and Safety Plan

- Labour Housing Plan

180000 Project

Cycle

Total (in USD) 1 202 000.00

9. CONSULTATIONS

Consultation were held with communities, Project Affected People (PAP), community leaders, local officials

& the district administrator on 7 December 2011 and on 23 September 2013 to ensure that all people are

included in the discussions, a total of 120 people in total attended the meetings. The objective of the meetings

were:

- To give PAPs a chance to have a say and express their views in the planning and implementation of the

project that affect them directly.

- For PDSA to understand the community needs in order to design relevant and sustainable income

generating activities for the community.

- To discuss the social value from the project (like school, employment, enhanced medical facilities, overall

economic development, stabilized livelihood, Initiatives for HIV/AIDS, vector diseases, Women Health

issues, Cattle Management, Drinking water and Food Security

- To inform local authorities of the impacts, agree on a cut-off date, solicit their views on the project and

discuss their share of the responsibility for the smooth functioning of the overall project operations.

Further consultations were carried out with the following stakeholders:

- District Administrator of Moamba

- Malengane Community

- Gowane Community

- Mwamongolonbi Community

- Mwamayanga Communities

Key concerns raised by communities mostly were focussed on how the project will benefit them. Specific

issues pertained to financial benefits once the project starts making profit, Job creation, irrigation of their own

farming areas, development of other areas for agricultural purposes by the community and provision of

alternative grazing land. In turn PDSA promised, provision of schools, development of access roads and

improvement of transport facilities, electricity supply for the area, development of health facilities, provision

of clean drinking water, vocational training facilities, special assistance to people from vulnerable groups such

as old people, people with disabilities, medically incapacitated people, assisting in developing community

centers and places of worship.

The concerns expressed were captured in a MoU which was signed between the communities Malengane,

Mwamungolombi and Mwamanhanga, the District Administrator and Pure Diets Mozambqiue SA on 18

October 2013. However, as the project progressed, PDMSA has not managed to fulfil all of the actions as

committed to in the MoU in the planned timeframe such as construction of water tanks and water lines,

construction of class room in two communities, construction of health centres, completion of electrical

transmission lines and this has led to some concern among the community members and if not addressed

adequately may lead to mistrust within the communities against the project. The main causes for the delays

are due to challenges faced by PDMSA such as change in the project’s management structure, change in the

community relationship team, and delay in mobilization of funds.

Nonetheless, PDMSA has now made some progress in terms of construction of temporary housing for PAPs

(to be completed by October 2015) and providing employment to the PAPs. The permanent housing

arrangement shall be completed within six months of temporary housing. PDMSA shall ensure the socio

economic development of the PAPs as per the requirement of regulations for the resettlement process resulting

from economic activities decree 31/2012 of 8 August Article 1- 28.

PDMSA has identified the following community activities to be completed on priority basis:

1 Ploughing Community Lands Ongoing- To be Completed by Nov 2015

2 Construction of 2 class room in Mwamayanga school To be Completed by Aug 2016

3 Construction of 1 class room in Mwamungolombi

school

To be Completed by Aug 2016

4 Construction of Water Tank in Mwamungolombi To be Completed by June 2016

5 Technical Training Programme for Youth

To be started from Jan 2016- Continual

Basis

6 Awareness programme on HIV / AIDS, Vector

diseases

To be started from March 2016- Monthly

Basis

7 Awareness programme on Women Health

To be started from March 2016- Monthly

Basis

8 Construction of Community Water Tanks Ongoing-To be Completed by April 2016

In order to ensure that corrective measures are taken, PDMSA has developed a Community Engagement Plan

(CEP) which lists all of the committed to activities as per the MoU as well as additional social development

activities that have not been included in the MoU but that will be undertaken as a result of the project. These

activities will be tracked with a completion timeline and progress update and PDMSA will be required to

report on the progress to the lenders on a regular basis.

10. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN (ESMP)

Standard operating procedure along with high quality pollution control equipment/plants shall be put in place

for managing environmental resources. Furthermore, environmental management plans have been

developed/proposed for the project to ensure appropriate procedures are in place to mitigate the negative

impacts identified in the ESIA. As part of the programme, specific control plans have been developed or

proposed for the following:

- Construction Environmental Management ;

- Worker Health and Safety Management;

- Biodiversity Management;

- Catchment Management;

- Speciality Study – Air Quality & Noise Modelling, Hydrological and Climate Studies;

- Environmental Monitoring Plans

- Waste Management, Reuse and Recycle;

- Carbon Emission/GHG Accounting;

- Environmental Pollution Control Equipment

- Archaeological and Historical Management;

- Community Engagement and CSR Management Plan

- Worker Health and Safety Plan

- Labour Housing Plan

- Traffic Risk and Safety Plan

- PDMS- Internal Regulation (Defining employment conditions and labour regulation)

- Approved by Government of Mozambique

(See Annexure for ESMP)

11. CONCLUSION

The negative environmental impacts that may result from the execution of this project can all be managed

through implementation of the ESMP (below).

12. CONTACTS:

1. Kelello Ntoampe, Environmental Scientist; Email: [email protected]; Ttel: +22520262708

2. Erika Auer, Senior Social Development Specialist. Email: [email protected]; Tel.: +225 2026 2269.

mailto:[email protected]

mailto:[email protected]

Annex 1: Environmental and Social Management and Monitoring Plan

Aspect, Potential

Impact/Issue

Actions to Mitigate Impacts Responsible Parties Means of Verification That

Commitment Has Been Met

Training/Resources

Required

Schedule for

Implementation

Related Plans

1. Construction Phase: Development of Sugarcane Plantation

Air Quality: Dust and GHG

emissions from land clearing, land

conversion (change in carbon

stocks) and planting activities.

o Dust suppression as needed, i.e.

watering disturbed areas during

dry and windy conditions;

o Ensure densification of vegetation

on fringes of cultivated lands (i.e.

Un-cleared forested area);

o Facilitate the planting of trees and

other afforestation to offset loss

associated with cleared areas;

o Avoid clearing trees which are in

a mature or climax state;

o Where feasible, practice no till

and/or minimum till at planting

Construction contractors supervised by

PDMSA’s HSE Team (to conduct visual

inspections);

Air Quality monitoring

program;

Daily visual inspections during

land clearing are done so that

vegetation remains dense along

fringes of cultivated land and

matured trees.

If necessary, consultant to

implement Air Quality

Monitoring program;

Training of construction

contractors with respect to

which vegetation and trees

should not be cleared and

where to use no till or use

minimum till planting

techniques

Air Quality Monitoring

Program to be carried out

over the entire construction

phase with daily readings of

dust emissions;

One time calculation of

expected GHG emissions

prior to clearing

Activities. Quarterly

monitoring of GHG.

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-

Environmental Policy

Soils: Erosion and sedimentation

from land preparation for new

agricultural and renovation of

existing fields for the sugarcane

plantation (vegetation clearance

and grubbing, ditch/drain

construction and canal

rehabilitation and expansion,

landscape grading and re-

contouring to ensure proper

drainage)

o Implement soil erosion, storm

water runoff and sediment control

measures, including the use of

appropriate best management

practices during clearance

activities. Best management

practices can include clearing

only small tracks of land at one

time and minimizing the length of

time that the cleared areas for

industrial use are void of

vegetation or for agriculture use

not under active cultivation;

o Schedule the majority of the

construction and land preparation

activities, to the extent

practicable, to occur in the dry

season and when land has been

appropriately drained, or by

Construction contractors are supervised by

PDMSA’s HSE Team; best practice forest

management enforced by relevant national

agencies;

PDMSA’s staff in charge of logistics to

schedule construction activities during

preferred times.

Awareness related education and training

program to be implemented by PDMSA’s

HSE Team.


vegetation clearance and

grubbing, ditch/drain


rehabilitation, landscape

grading and re-contouring to

ensure that erosion

and sedimentation are

minimized by construction

contractors.


contractors on soil erosion,

storm water runoff and

sedimentation control

measures (i.e. clearing small

tracks)

Training to be

conducted prior to earth

movement/land

clearing activities

Daily visual inspections to

be carried out during periods

of significant land

preparation

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


limiting off-road access and by

implementing an awareness

education and training program;

Water Quality: Impacts on

Surface water quality

o Protect all areas susceptible to

erosion by installing necessary

temporary and permanent

drainage works as soon as

possible and by taking any other

measures necessary to prevent

storm water from concentrating in

streams and scouring slopes and

steep banks.




agencies



preferred times.



HSE Team.







ensure that erosion



contractors






tracks)

Training to be


movement/land

clearing activities



of significant land

preparation

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Water Quality: Increases in

turbidity and salinity in surface

water from releases of turbid water

due to the physical disturbance of

soil during earthmoving activities,

brackish discharges from saline

soils disturbed by earthmoving and

acidic drainage from pseudo-acid

sulphate soils in the north block.

o Any runnels or erosion channels

developed during the construction

or maintenance period shall be

backfilled and compacted and the

areas restored to a proper

condition similar to the condition

before the erosion occurrence

o Prevent storm water damage, the

increase in storm water runoff

resulting from the construction

activities must be estimated and

the drainage system accessed

accordingly.




agencies



preferred times.



HSE Team.







ensure that erosion



contractors






tracks)

Training to be


movement/land

clearing activities



of significant land

preparation

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Terrestrial Biological Resources:

The permanent loss of the MFM,

SSMFP, MHFS, SWE and SWP

habitats

o Include a 50-100 meter wide

buffer area along the Inkomati

River to preserve a band of

natural, seasonally flooded habitat

within the most species rich and

diverse habitats.

PDMSA to ensure buffer is maintained

during construction; biological resource

management enforced by LAW and

overseen by conservation institutions.

Periodic visual inspections to

ensure buffer is being properly

maintained during land clearing

activities.


contractors with respect to

the buffer area that should

be maintained and the

importance of this buffer

Training to be


movement/land

clearing activities and

refreshed bi-annually

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

Terrestrial Biological Resources: Habitat degradation from

Hazardous Material Spills

o Containment of oil, fuel and

chemicals with bunds or similar

devices.

o A Spill Management Plan will be

developed and implemented,

which will contain specific

measures for safe handling and

storage of hazardous materials.

PDMSA’s HSE Team and Construction

contractors supervised by PDMSA; proper

management of hazardous materials

enforced by LAW


ensure proper management and

handling of hazardous

materials; any evidence of

significant spills or poor

management to be

photographed and logged in an

HSE database


contractors and PDMSA

employees on management

of hazardous materials and

Spill Prevention and

Countermeasures (SPCC)

Plan

Training to be conducted

prior to use of hazardous

materials and refreshed

quarterly

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

Terrestrial Biological Resources: Mortality, disturbance,

displacement, or injury to wildlife

caused by vehicular traffic,

construction equipment,

construction workers and the loss

of habitat.

o Enforcement of speed limits on

roads to minimize vehicular

collisions with wildlife and driver

education trainings to reduce

wildlife injury and mortality;

o Worker education on the species

of concern in the area and how to

avoid impacting them;

o Maintain corridors to allow

movement of large mammals.

PDMSA to coordinate with local authorities

to enforce speed limits

PDMSA to implement driver education

program, emphasizing the importance of

obeying traffic laws

PDMSA’s HSE Team to implement training

on species of concern and mitigating

impacts to those species

PDMSA’s HSE Team (or biologist

contractor) to implement Biodiversity

Monitoring Program which will monitor

migration corridors

Database tracking traffic related

infractions

Documentation of driver and

wildlife management training

provided and attendance

records of those training events

Implementation of Biodiversity

Monitoring Program, which

includes visual inspection of

wildlife corridors and records

signs of disturbance (i.e.

movement into other areas) and

incidences of mortality

Driver safety training to all

workers, including

contractors, who are

expected to drive as part of

their duties.

Integration of a worker

fatigue and stress

management program for

long haul truck drivers.

If necessary, procurement of

expert biologist consultant

to implement Biodiversity

Monitoring program


prior to the start of transport

activities or land movement

and refreshed quarterly

Worker fatigue and stress

management program to be

implemented on an on-

going basis but initiated


activities

Biodiversity Monitoring

activities to be conducted

monthly, or as needed,

during construction

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

Terrestrial Biological Resources: Impacts (such as those mentioned

above to general wildlife) to

observed species of concern near

Inkomati River

o See mitigation involving buffer

area and worker education above

as they apply to protecting species

of concern

See above




impacts to species of concern

See above



includes tracking the presence

of species of concern and

evaluating effectiveness of

mitigation measures to protect

species of concern

See above




Monitoring program



monthly, or as needed,

during construction

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

Aquatic Resources: Increased

turbidity in the vicinity of the river

o Conduct Canal and other

connected waterway maintenance

activities during periods of high

PDMSA to supervise contractor procured

for maintenance to ensure activities are

conducted during high flow

Supervision of maintenance

activities will confirm the


consultant to implement

Water Monitoring program

Water Monitoring activities

to be conducted monthly, or

Annexure 25 –P3-

Construction

from suspension of clay when the

irrigation canal is widened.

flow in the Inkomati River, which

would increase dilution potential

downstream of the Canal.

implementation of activities

during periods of high flow.

Water Monitoring Program will

track turbidity levels at mouth

of the Canal

as needed, during

construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan )

Aspect, Potential

Impact/Issue

Actions to Mitigate Impacts Responsible Parties

Means of Verification That

Commitment Has Been Met

Training/Resources

Required

Schedule for

Implementation

Related Plans

Aquatic Resources: Impacts to

aquatic resources as a result of

changes in water quality (DO,

conductivity, pH) mainly from

increased turbidity

o See mitigation measures above

related to erosion and

sedimentation.

PDMSA’s HSE Team (or contractor) to

implement Water Monitoring Program

which will monitor changes in water quality

Water Monitoring Program will

track changes in water quality

both inside and outside of the

Project Area


Program will track changes in

overall presence and condition

of aquatic resources


consultants to implement

Water and Biodiversity

Monitoring programs

Water and Biodiversity

Monitoring activities to be

conducted monthly, or as

needed during construction

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

2. Construction Phase: Construction of Organic Sugar Production Facility

Air Quality: Dust emissions from

land clearing/ preparation of plant

area, grading of access roads,

excavation and increased vehicle

traffic on unpaved roads

o Dust suppression as needed, i.e.

watering disturbed areas during

dry and windy conditions

Construction contractors supervised by

PDMSA’s HSE Team(to conduct visual

inspections)

Air Quality monitoring program If necessary, procurement of

consultant to implement Air

Quality Monitoring

program


Program to be carried out

over the entire construction

phase with daily readings of

dust emissions

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Soil: Erosion and sedimentation

from the construction of the various

industrial facilities.

o See mitigation measures above

for erosion and sedimentation

under “Development of the

sugarcane plantation” as they

apply to the construction of the

processing facility as well

See Above See Above See Above See Above Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

3. Operations Phase: Operation of Sugarcane Plantation

Air Quality: Combustion

emissions (including GHG; CO2,

CH4 and

N2O) from machinery

used for cultivating and harvesting

(non-road mobile diesel engines),

from mobile drainage pumps and

portable irrigation pumps (internal

combustion engines)

o Ensure use of well maintained,

high efficiency diesel motors for

the portable irrigation pumps and

mobile drainage pumps

o Ensure maximum efficiency of

tractor passes per hectare during

cultivation and crop maintenance;

PDMSA responsible for procuring high

quality equipment and overseeing that

operation contractors use and maintain

equipment according to manufacturer’s

specifications and maximize efficiency of

tractor passes

Air Quality monitoring program If necessary, procurement of


Quality Monitoring

program

Training of operation

contractors on maintenance

of motors and pumps,

identifying problems with

equipment and measures for

maximizing efficiency of

tractor passes

Initial investment required

for high efficiency

equipment

Initial selection of high

efficiency motors to be

made during project design

as a result of the alternatives

analysis


Program to be implemented

quarterly during operation

Training on equipment

maintenance and tractor

passes to be issued prior to

the operation phase

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Soil: Soil contamination from spills

or leaks of lubricants, fuels and

other chemicals, mainly pesticides

and herbicides that will be used

during the operation of the

plantation.

o Use of improved equipment, such

as chain drags between bulldozers

and the use of root rakes, floating

blades and careful /

knowledgeable equipment

operators

o Spill control will be exercised by

inspecting equipment, hiring

trained and dedicated feelers and

pesticides/herbicides handlers and

by implementing a Spill measures

described measures to be

implemented by PDMSA and its

contractors to prevent and if

PDMSA is responsible for procuring high

quality equipment and overseeing that

operation contractors use and maintain


specifications


ensure adequate spill control

measures are in place and

elements of the SPCC Plan are

generally being implemented


contractors on (i) best

practice use & maintenance

of equipment to reduce soil

contamination from spills;

(ii) management of

hazardous materials and

Spill Prevention and

Countermeasures (SPCC)

Plan; (iii) aerial spraying of

herbicides and pesticides to

minimize application on

sensitive habitats and ensure

best practice handling of

these chemicals


prior to the start of operation

and be refreshed as needed

based on results of the

inspections

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


necessary, contain and control

inadvertent spill of hazardous

material such as fuels, lubricants

and pesticides chemicals,

containment walls and other

measures. In addition, a training

module will be developed to

educate employees on the SPCC

Plan;

Terrestrial Biological Resources: Diminished use of habitat by

reducing hiding places and safe

havens for large predators and prey

from the repeated harvesting

activities of the cane crop. The

planting and harvest activities

themselves will disturb the

mammal and bird fauna. The large

mammal fauna will likely move

and retreat into the surrounding

areas.

o Maintain a 50-100 meter buffer

area along the Inkomati River to

allow undisturbed areas for

wildlife.

o Maintaining corridors to allow for

movement of large mammals.

PDMSA to ensure buffer is maintained

during operation; biological resource

management enforced by LAW and

overseen by conservation institutions (e.g.

STINASU, SCF, NCD)




migration corridors


ensure buffer is being properly

maintained during planting and

harvesting activities.



includes visual inspection of

wildlife corridors and records

signs of disturbance (i.e.

movement into other areas) and

incidences of mortality


contractors as to the buffer

area that should be

maintained and the

importance of this buffer




Monitoring program


prior to planting and

harvesting activities that

may disturb the buffer



quarterly, or as needed,

during operation

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

Terrestrial Biological Resources

l: Introduction and/or increase in

rodent populations related to

sugarcane population

o Implement a Rodent Management

Plan including active rodent

trapping and coordination with

local health care providers to

establish procedures to address

any incidence of rodent-borne

disease.

Agricultural Project team lead Regular recordkeeping of

number and location of rodents

trapped

Training of agricultural team

in rodent control and

concerns regarding rodent

infestation for the sugarcane

crop and nearby rice

cultivation.

Monthly monitoring,

quarterly consultation with

local health authorities

regarding incidence of

rodent borne disease in the

Malangane community

Annexure 25 –P3-

Construction

Environmental

Management Plan

PDMSA-


Annexure 25 –P6-

Biodiversity

Management Plan

4. Operation Phase: Operation of Organic Sugar Production Facility

Soil: Soil contamination from spills

or leaks of lubricants and fuels and

other chemicals that will be used

during the operation of the plant.

o See first two (2) mitigation

measures above for soil

contamination under “Operation

of the sugarcane plantation” as

See Above See Above See Above See Above Annexure 25 –P3-

Construction

Environmental

Management Plan

they apply as well to the operation

of the processing facility.

PDMSA-


Air Quality: Combustion

emissions (including GHG; CO2,

CH4 and N2O) from bagasse and

trash- fired COGENERATION

plant at

o Use of new bagasse and trash-

fired COGENERATION plant

with high energy efficiency

boilers;

o Regular maintenance of the

boilers and all equipment;

PDMSA responsible for installing engineer

controls to reduce combustion emissions

and maximize efficiency of conversion

process. They are also responsible for

researching and implementing


Program

Tracking energy use through

electric bills and periodic

visual inspections of work

areas;



Quality Monitoring program



Initial selection of high

efficiency equipment to be



analysis

Installation of

Electrostatic Precipitator

the factory (boiler stack) and from

on road diesel engines of trucks

transporting cane, raw sugar to and

from the facility.

o Installation of emission reduction

systems such as wet scrubbers on

the boilers.

o Location of factory at the center

of the Project Area to minimize

traveling distance for trucks

transporting cane to factory and

ultimately minimizing diesel

consumption;

o Use of bagasse (90 percent) and

trash (10 percent) as fuel for the

COGENERATION plant boilers

to produce onsite power and heat

requirements (renewable fuel);

o Selling of excess renewable

power (at least 9 MW - base load)

to external fossil-fuelled plant at

the Moamba District;

o Where feasible, implement carbon

emission offsets elsewhere (e.g.

developing the Project as a carbon

development mechanism (CDM)

project and obtaining emission

reduction credits).

o Ensure use of energy efficient

lighting, heating and ventilation at

factory site;

o Ensure adequate maintenance of

all transport vehicles.

carbon emission offsets (to the extent

possible)

PDMSA’s HSE Team (or air quality

contractor) to implement Air Quality

Monitoring Program

Operation contractors supervised by

PDMSA, responsible for maintenance of


specifications and efficient use of energy

Transport contractors supervised by


transport vehicles according to

manufacturer’s specifications

energy used in conversion

process to

be evaluated separately

Tracking quantity of excess

renewable power sold to fossil-

fuelled plant at Moamba

District

Documentation of offset

program and emission reduction

credits received

Sporadic emissions testing of

transport vehicles to ensure

adequate maintenance; tracking

maintenance records

of boilers and other

equipment

Training of transport


of transport vehicles

Initial investment required

for high efficiency

equipment


Program to be implemented

quarterly during operation

Training on equipment and

vehicle maintenance to be

issued prior to the start of

operation and refreshed as

needed

Energy efficiency to be

monitored over the life of

the Project

Wet Scrubber

High Volume Sampler

for Air Quality

Monitoring

Annexure 26

Environmental Control

Machinery

Specifications

Noise: Movement of trucks (i.e.

transport of raw sugar) along the

Transport Corridor will result in

increased noise levels at nearby

receptors along the corridor (which

includes residences, schools and

houses of worship).

o Regular maintenance of all trucks

in accordance with

manufacturer’s specifications;

o Install sound suppressive devices

(such as mufflers) on the trucks;

o Educate truck drivers and ensure

they do not exceed a speed limit

of 45 km along densely populated

areas along the corridor.


controls to reduce noise emissions

PDMSA’s HSE Team (or noise contractor)

to implement Noise Monitoring Program

Transport contractors, supervised by







Noise Monitoring

Program

Documentation of driver

training provided and

attendance records of those

training events


infractions


workers, including



their duties.


noise consultant to

implement Noise

Monitoring program

Initial selection of

engineering controls to be



analysis



activities and refreshed

quarterly

Noise Monitoring activities


as needed during operation

Machine Acoustics

Chamber

PPE

Installation of Noise

Monitoring Equipment

Noise: Movement of trucks (i.e.

transport of raw sugar) along the

Transport Corridor will result in

increased noise levels at nearby

receptors along the corridor (which

includes residences, schools and

houses of worship).

o Regular maintenance of all trucks

in accordance with

manufacturer’s specifications;

o Install sound suppressive devices

(such as mufflers) on the trucks;

o Educate truck drivers and ensure

they do not exceed a speed limit

of 45 km along densely populated

areas along the corridor.


controls to reduce noise emissions

PDMSA’s HSE Team (or noise contractor)

to implement Noise Monitoring Program

Transport contractors, supervised by







Noise Monitoring

Program

Documentation of driver

training provided and

attendance records of those

training events


infractions


workers, including



their duties.


noise consultant to

implement Noise

Monitoring program

Initial selection of

engineering controls to be



analysis



activities and refreshed

quarterly

Noise Monitoring activities


as needed during operation

Machine Acoustics

Chamber

PPE

Installation of Noise

Monitoring Equipment

5. Decommissioning Phase: Closure of Sugarcane Plantation

Retrenchment: Reduction in

workforce during closure period,

with related indirect effects to

secondary economy

o Implement policies and programs

to assist retrenched workers.

Assistance should include career

counselling, training programs

and economic development

opportunities based on level of

skills and type of contract.

-PDMSA HR team to ensure company

policies regarding terms of employment

which may affect retrenchment benefits are

built into employment contracts and

disclosed to workers upon hire.

- Prior to expected retrenchment, PDMSA

HR and CR teams to consult with the

workforce and their representatives and

with local communities where workers live

(Malangane and) to provide information and

Semi-annual monitoring of

retrenched workers, to establish

the outcomes of assistance that

was provided

Records and periodic audits of

reference material, including

written records of consultations

with retrenched workers

Accrual funds necessary to

provide career counselling,

finance retraining and

economic development

program.

Training programs for

retrenched workers should

be established prior to the

closure phase. Based on

consultation with the

community, the training

program should seek to fill

the most pressing skill gaps.

Conceptual Closure

Plan (To be developed

and submitted for lender

review)

receive feedback on the retrenchment

process.

- They should ensure that workforce and

communities are notified of scope, scale and

schedule of anticipated retrenchment in a

timely and suitable manner and are

consulted about options for potential

retraining/economic development/job

placement programs and other support to be

offered

6. Decommissioning Phase: Closure of Organic Sugar Production Facility

No significant impacts associated with the closure of the sugar processing and production facility have been identified

Social/Labour: Project- related

grievances from local communities

or other project-affected

stakeholders

o Upgrade existing PDMSA

Grievance Procedure in line with

international standards

o Consult with local communities

and other stakeholders

communities in project area of

influence) to inform decisions

about the range of options to be

established for receiving and

resolving grievances. Consider

cultural expectations and norms

for communication and problem-

solving related to grievances

o Disclose the grievance

mechanism widely among local

and potentially affected

stakeholders via locally and

culturally appropriate channels

PDMSA Community Relations team, in

coordination with HR team for labour-

related grievances

Ongoing monitoring of

mechanism effectiveness, for

example:

o Number of grievances

received according to

category, per time period

o Number and % closed

according to category, per

time period

o Number of satisfied

responses from

complainants, per

category, per time period

o Identified root causes of

resolved grievances

o Timeframes for closure of

grievances by category

o Repeats of the same

grievance

Training of community

relations staff on the details

of operating the Grievance

Mechanism

Training for all about the

Grievance Mechanism, its

basic elements and what to

do if contacted by a

stakeholder with a project

staff on the compliant

Review and upgrade

(including consultations) of

PDMSA’s existing

grievance procedure to

commence as soon as

possible, prior to

construction

Communicate the Grievance

Mechanism to internal and

external stakeholders by

start of construction and

repeatedly throughout life of

project

Conduct ongoing

monitoring against

established performance

indicators and periodic

reviews of the overall

functioning of the

mechanism and areas for

improvement

Grievance Mechanism

(Stakeholder grievance

management policy)- To

be made available in

local language

Ecosystem Services: The project’s

changes to local hydrology and

ongoing use of water including

o Continue ongoing collaboration

with Ministry of Agriculture and

local water boards in order to: (i)

PDMSA’s Environment team is primarily

responsible for implementing the Water

Management Plan.

Documentation of engagement,

tracking of water-related

grievances

To be Determined To be Determined Continue ongoing

collaboration with

Ministry of Agriculture

water intakes from the Inkomati

river and discharges into the

Inkomati River– will impact

various ecosystem services used by

local and downstream

communities, including water

quality and availability for

domestic and agricultural uses,

fisheries and natural flood

regulation.

Disclose the Project’s Water

Management Plan and

procedures; (ii) Maintain open

communication with other water

users in the Project Area; (iii)

Identify and immediately resolve

any unanticipated negative

impacts to downstream water

users as a result of the Project;

and (iv) Ensure compliance with

local water use regulations and/or

collaborative management

strategies established by the

Ministry.

The Community Relations team should be

involved in all elements related to

stakeholder engagement and information

disclosure.

and local water boards

on water management

issues

Social: Population influx and

associated negative social impacts

due to creation of jobs in

connection with the project

o Establish a Local Content Plan

outlining targets and a program to

achieve them, for number of local

labourers, as deemed appropriate

based on consultations with the

community regarding project-

related benefits for that

community) in each stage of

Project lifecycle;

o Establish, as part of the Local

Content Plan, guidelines to

encourage the procurement of

local goods and services

o In partnership with local

agricultural education

organizations, establish Skills

Training and Development

Program to increase the number

of skilled agricultural workers in

the local Labour market.

For Local Content Plan:

o PDMSA HR team to develop and

implement the plan, including

tracking progress towards hiring and

retention targets for local labourers.

o Procurement team to coordinate with

HR on development and

implementation of guidelines for local

procurement.

For Skills Training and

Development Program:

o PDMSA’s CR team to establish

relationships between the Project and

local agricultural educational

organizations.

o PDMSA’s HR team to develop

training programs to help boost the

capacity of agricultural workers.

For Local Content Plan:

o Actual number of local

labourers employed

versus the target number.

o Establishment and

continuous updating of

database on goods and

services that are available

locally

o Monitoring of percent

value and volume of

locally produced goods

and services procured

For Skills Training and

Development Program:

o Number of graduates of

training courses per

session

o Percent of skills training

program graduates

retained by PDMSA

o Number of participants

and graduates of

programs that adopt new

Implementation of

Technical Skills Training

Program to ensure local

Labour market is qualified

for employment (see below)

Training of human resources

and procurement officers to

guide hiring and

procurement protocols

Development of

partnerships with local

agricultural educational

organizations

Plans to be developed as

soon as possible

Training of HR and

procurement staff on

implementation of Local

Content Plan and Skills


Program as applicable, prior

to initiation of construction

activities and continuing

throughout project lifecycle

as appropriate.

Monthly monitoring and

reporting of actual

performance vs. established

performance indicators.

Yearly monitoring of

agricultural workers who are

trained to ascertain how

their skills or agricultural

practices have changed.

Local Content Program

((To be developed and

submitted for lender

review- Prior to Labour

Mobilization)

Annexure 25-P5-

Community

Engagement & CSR

Plan

PDMSA- OHS Policy

PDMSA- Social

Accountability Policy

technologies or

agricultural methods

Social: Local capacity is

insufficient to staff Project

managerial and technical positions.

Without a program to develop local

capacity and leadership ability, the

Project will remain dependent on

expatriate workers.

o Establish an Internal Leadership


Program to increase capacity of

Mozambican staff and train local

staff in administrative, managerial

and technical positions in order to

replace expatriate positions within

10 years of Project operations.

The PDMSA HR team is responsible for

ensuring that the appropriate training tools

are in place and that the local staff has

access to resources and programs to develop

their job skills and leadership ability.

Number of Mozambican

employees who have received

appropriate training for their

respective and target positions

Percent of those who have

received training (per

subcategory) who have been

hired on full-time in an

administrative, managerial or

technical role

Number of expatriate staff and

their percentage within all

administrative, managerial and

technical project staff

Implementation of an

Internal Leadership Training

and Development Program

to aid the transition from

expatriate workers to local

staff.

If necessary, training of

human resources officers or

employees who will develop

and implement the training

and leadership development

program.

Training should commence

during the operation phase.

Local staff should be given

the opportunity to shadow

expatriate staff and formal

structures should be set up

where local staff can ask

questions to and receive

feedback from expatriate

staff.

Internal Leadership

Training and

Development Program

as CSR Plan

Local Content Program

((To be developed and



Mobilization)

Social: Project workers and

contractors will put new demands

on the local housing market in

Malangane and may generate social

conflict and tensions with local

community members, as well as

potentially leading to changes to

local land use due to new housing

construction.

o Evaluate the availability and

quality of existing housing in

Malangane, to determine whether

sufficient adequate housing exists

to accommodate Project-related

influx and to identify any critical

concerns and issues to manage in

association with the housing of

incoming workers.

o Based on evaluation findings,

establish a Worker Housing and

Integration Plan including

procedures and actions to

facilitate the integration of new

staff into Malangane and to dis-

incentivize new land colonization,

especially in areas which may

generate social conflict.

o Specify within the project’s

Labour Management Plan a

company policy on worker

The PDMSA Human Resources (HR) team

will be responsible for ensuring that

behavioural guidelines are in place for

Project workers

The PDMSA Health and Safety team is

responsible for ensuring that appropriate

health and safety provisions are in place for

worker housing. The team should draft

health and safety guidelines that will be

used to monitor the conditions in worker

housing.

The Health and Safety team together with

the Community Relations team is

responsible for the Community Health and

Safety Plan.

Location and quality of worker

housing, including compliance

with health and safety

guidelines,

tenancy information, training

completion

rates on Worker Code of

Conduct, health monitoring and

additional parameters to be

defined in Worker Housing and

Integration Plan and

Community Health and Safety

Plan

Resources should be

available to ensure workers

have access to health-risk

preventive measures, such

as mosquito nets and

contraception, including

condoms.

If necessary, a training

program should be held to

sensitize workers to the

dangers of substance abuse.

If necessary, a training

program should be

established on health and

safety protocols. The

program should be updated

on a semi-annual basis.

Annexure 25-P2 Labour

Housing Plan

Annexure 25-P4 Worker

Health & Safety

management Plan

Annexure 25-P1-

PDMSA Internal

Regulation

PDMSAS Social


housing, including a Worker Code

of Conduct for behaviour within

company-owned housing

o Establish a Community Health

and Safety Plan to minimize,

monitor and manage health

impacts to the local community

caused by the influx of what will

likely be a mostly male

workforce.

Social: Expected population influx

related to Project activities will

likely put a strain on existing social

and public services in the area.

o Establish local and regional

planning initiatives in the Project

Area in association with the

community and local authorities.

The initiatives should focus on

improving public service

provision in the project area to

offset the additional burden to

these services caused by in-

migration.

The PDMSA will aid in coordinating the

voluntary activities related to planning

initiatives, including providing advanced

notification of issues related to workforce

and community interaction.

Joint tracking (with local

authorities) of enrolment /

utilization rates of local and

regional social and public

services

Indicators to measure

successful service provision (to

be established)

Accrual funds may be

necessary to finance the

proposed initiatives and

program established.

Consultations should be held

prior to the beginning of

construction to establish

priority initiatives and

services requiring potential

collaboration.

During construction and

operation, planning sessions

should be arranged semi-

annually to determine and

refresh initiatives.

NA

Social: Affected communities and

other stakeholders need to be

informed about and provided the

opportunity to offer views and

opinions on the management of

impacts and risks associated with

the Project. Building trust by

providing opportunities for

stakeholders to be informed and

express their concerns and

suggestions and by taking their

input into account, is an important

component of managing social,

reputational and operational risks.

o Develop a Public Disclosure and

Consultation Plan that establishes

guidelines for consulting and

engaging the local community,

both during project planning and

throughout the life of the project.

The Plan should ensure that

affected groups are notified and

consulted on Project risks,

impacts and other issues that may

affected them. During the Project

lifecycle, affected groups should

be informed about changes to the

Project scope and schedule.

o Within the Public Disclosure and

Consultation Plan, ensure

consideration of the special needs

The PDMSA CR team is responsible for

communicating and engaging with key

stakeholder groups about Project activities

and impacts. They should ensure that

Project communication is accessible and

understandable to different groups of the

affected community and that different

segments of the community are represented

in the consultation process.

Dates, type, nature and

frequency of consultations and

interactions with local

community members and other

stakeholders (tracked by type /

individual)

Responses offered or

commitments made in response

to stakeholder questions and

concerns

Training for CR staff on

implementing the

Public Disclosure and

Consultation Plan

The disclosure and

consultation/engagement

process should be a

constantly evolving process

throughout the Project

lifecycle and should be

periodically updated to

account for changing

stakeholders and Project

information.

Annexure 27-MoU

Commitment with the

Communities

- Local Content

Program ((To be

developed and



Mobilization)

-Annexure 25-P5-

Community

Engagement & CSR

Plan

-PDMSA- OHS Policy

-PDMSA- Social


and unique characteristics the

community in, as well as other

vulnerable groups in the project

area of influence, to ensure they

have adequate opportunity to

express their opinions and views.

o With respect to, Stakeholder

Engagement should ensure

cultural appropriateness and lead

to Broad Community Support.

Social: Violations of Labour rights,

or inappropriate worker conduct in

local communities, can cause

social, legal and operational risks

to the project, if not effectively

managed. In addition, major

Labour violations (such as

employment of child or forced

labour) among key suppliers may

cause reputational risks to PDMSA.

o Establish a Labour Management

Plan, encompassing the project’s

human resource policies,

procedures and systems to uphold

worker rights in accordance with

applicable national laws,

communicate with and engage

workers and ensure they are

adequately trained and equipped

to perform their jobs in a safe

manner.

o The Plan should include an

Occupational Health and Safety

Program covering all such related

risks to workers. A Worker Code

of Conduct that sets guidelines

and requirements for interactions

between workers and the

community should be included in

the Plan.

o A grievance mechanism should be

in place that allows the project to

address allegations of non-

compliance with established

policies.

PDMSA’s HR team will have primary

responsibility for implementing the Labour

Management Plan.

The HR team should collaborate with the

Health and Safety team to develop and

implement the Occupational Health and

Safety Program.

The HR team should collaborate with the

Community Relations team to implement

the grievance mechanism.

-Monitoring of company and

contractor compliance with the

company policies and local

laws;

-Numbers of Labour related

grievances filed each quarter;

types of issues raised and by

whom; and percent resolved by

type;

-Occupational Health and

Safety monitoring against

indicators to be established

through the development of the

OHS Program;

-Quarterly audits of working

conditions and to verify there

are no cases of child Labour or

forced Labour at the Project

site.

If necessary, training on

national employment and

Labour laws.

Health and safety training to

promote safe working

conditions.

Worker policies and

procedures should be

established prior to the

beginning of the

construction phase. The

policies should reflect

company and national

standards and should be

updated throughout the

Project lifecycle.

Annexure 25-P1-

PDMSA – Internal

Regulation- Approved

by Ministry of Labour

Government of

Mozambique

Annexure 25-P4-

Worker Health & Safety

Management Plan

Annexure14- HSE

clause –EPC Contractor

Social: Accidents and incidents

may occur within the Project site

and/or may affect neighbouring

communities.

o Establish Emergency

Preparedness and Response Plan

to cover the risks and hazards that

may result in emergency

situations and the required

response to these emergencies.

o Develop an Occupational Health

and Safety Program to minimize

and manage health and safety

risks to workers on site.

o Establish a Community Health

and Safety Plan to outline

additional measures related

specifically to dealing with

emergencies or incidents that

affect local communities.

o Identify and train personnel to

lead emergency situations and

ensure provision of appropriate

emergency preparedness and

response equipment and supplies.

o Share relevant information with

and train local communities and

government authorities as

appropriate (including involving

them in simulations of emergency

situations which may affect

them), to ensure their capacity to

assist or cooperate with response

efforts as needed.

The PDMSA Health and Safety (H&S)

team is responsible for identifying and

establishing roles for emergency response

participants. The H&S team should keep a

constantly updated log of emergency

situations that occur and update the Plan to

reflect the current Project lifecycle.

Development and implementation of the

Community Health and Safety Plan should

be coordinated among the H&S Team, the

Environment Team and the Project’s CR

team.

Quarterly audits to

verify that all active workers

and contractors have received

Emergency Preparedness and

Response training and know the

protocols during an emergency

situation;

Number of trainings and

simulations offered for

communities and local

government staff and number of

participants

completing each training;

OHS and Community Health

and Safety monitoring

indicators (to be developed as

part of OHS and CHS

programs);

Ongoing maintenance

/ auditing of emergency

response. equipment

Establishment and training

of Emergency Coordinators

and teams on emergency

response protocols

Training and simulations

with local communities and

local authorities on

emergency response

procedures and measures

The Emergency

Preparedness and Response

Plan and Community Health

and

Safety Plan should be

established in consultation

with local communities and

government authorities

during the ESIA progress.

The Plan should be in place

at the inception of

construction activities and

updated throughout the

Project lifecycle.

Emergency

Preparedness and

Response Plan((To be

developed and



Mobilization)

Annexure 25-P4-

Worker Health & Safety

Plan

PDMSA- Occupational

Health & Safety policy

Annexure14- HSE


Waste: Hazardous materials,

including petroleum products,

will be used, stored and handled

o Establish a Hazardous Materials

Management Plan outlining

requirements and procedures to

The PDMSA Environment and Health and

Safety teams are responsible for

-Quarterly audits against

indicators to be established in

the Hazardous Materials

Training for workers and

contractors who may handle

or come into contact with

Establish plan prior to the

start of construction;

Annexure 25 –P3-

Construction

by the Project. Without proper

controls, hazardous materials

can impact the safety of the

workforce and surrounding

communities through spills,

accidental releases and/or

explosions.

safely manage, store and utilize

hazardous material, including

agricultural and pest-control

chemicals and inputs. The Plan

should comply with specific

requirements as outlined in IFC’s

HSE Guidelines.

o Establish transportation

guidelines for the transport and

storage of hazardous material,

including transporting material on

routes and during times to

minimize public exposure.

o Ensure that all hazardous

materials are clearly identifiable

and labelled.

o Coordinate the Plan with the

Emergency Preparedness and

Response Plan and the

Community Health and Safety

Plan, particular with respect to

disclosure of hazardous materials

related risks and disclosure /

training on emergency response

measures in the event of an

accidental release, spill or

explosion.

establishing training, signage and storage

procedures for hazardous material.

The Community Relations team should

disclose and consult with local communities

and authorities on what hazardous materials

are being used in Project area, the risks

associated with the materials and

emergency response measures in the event

of a spill.

Management Plan, to verify that

all hazardous materials are

being properly handled and

stored;

-Records of all workers and

contractors that have received

the hazardous materials training

plus ongoing refresher courses;

-Root cause analyses and

corrective actions taken in the

event of an incident and

ongoing environmental

monitoring as needed following

a release of hazardous materials

into the environment

hazardous materials and

emergency actions to follow

in the event of spillage,

release or accidents. The

training may occur in

coordination with

Emergency Preparedness

and Response training.

implement throughout the

project lifecycle

Environmental

Management Plan

PDMSA-


Transportation: The Project

requires the transportation of

people, supplies, products and

wastes (including hazardous

materials) to, from and within

the Project area. Transportation

will make use of public road

o Conduct a Traffic Risk

Assessment, including a

description of the scope of

Project-related traffic and

identification of all areas sensitive

The Traffic Risk Assessment should be

carried out by competent professionals with

experience in traffic issues. The CR team

should be engaged during the assessment

process, to conduct consultations with local

authorities and other key stakeholders who

can provide local perspectives on traffic-

Quarterly audits to check that

Project drivers meet necessary

licensing requirements and are

aware of the traffic regulations

If necessary, driver training

on national traffic

regulations should be held

on an annual basis.

If necessary, driver training

on proper vehicle

The Transportation Health

and Safety Plan should be in

place prior to the

commencement of

transportation activities and

should be reviewed and

updated annually.

Traffic Risk Assessment

& Safety Plan (to be

developed and


review before start of

construction)

infrastructure, which passes

through various communities.

Traffic-related accidents may in

turn pose a risk to the health,

safety and quality of life of those

communities.

to traffic risks and the current

state of road repair.

o Based on the Traffic Risk

Assessment, develop and

implement a Road Maintenance

and Monitoring Plan to be

implemented in coordination with

local authorities to ensure that any

deterioration in the quality of the

Road caused by the Project is

identified and immediately

repaired

o Develop a Transportation Health

and Safety Plan establishing the

policies and procedures to

manage driver conduct, training

and health and safety measures.

The Plan should include

requirements and management

measures to ensure Project-

related transit is conducted safety,

including speed limits, vehicle

maintenance and requirements

related to night time driving.

o A roster of drivers should be

available and maximum shift

lengths established, to prevent

driver fatigue.

related risks and necessary management

approaches.

The Road Maintenance and Monitoring

Plan should be developed and implemented

jointly with local transit authorities.

The PDMSA Health and Safety and

Logistics teams are responsible for

developing and implementing the

Transportation Health and Safety Plan,

including ensuring proper licensing of

drivers and full knowledge of national

traffic regulations.

Semi-annual audits to check the

maintenance of Project and

contractor vehicles.

Road maintenance monitoring,

as per parameters to be

established within the Road

Maintenance and Monitoring

Plan.

maintenance should be held

to help ensure vehicles are

in proper working condition.

PDMSA- Occupational

Health & Safety Policy

Annexure14- HSE


Documents

Mozambique - Organic sugar project of pure diets Mozambique S.A