MIGA's due diligence review considered the environmental and social management planning process and project documentation and identified any gaps between these requirements and MIGA's requirements. Any corrective actions that may be required to close these gaps in a reasonable time are summarized in the following paragraphs and in theEnvironmental and Social Action Plan (PAAS)attached to this ESRS. With the implementation of these measures, it is expected that the project will be designed and operated in accordance with the performance standards.
The main environmental and social (E&S) issues related to the project's business activities are summarized in the following sections.
PS1: Assessment and management of environmental and social risks and impacts
Environmental and social policy:
Tatweer has developed a Health & Safety (H&S) policy which is supported by management. This policy recognizes the importance of a healthy workforce to business success and commits Tatweer to providing and maintaining a safe and healthy workplace for all employees. It also states that Tatweer will inform, guide and supervise employees, investors and visitors in the areas of safety and health. SEZAD and Tatweer plan to improve the H&S policy document as part of the Environmental and Social Management System (ESMS) to also include environmental issues and extend the scope of this policy to contractors, third parties and potential tenants (as per ESAP).
Environmental and Social Assessment and Management System:
In March 2017, SEZAD issued its own Environmental Impact Assessment (EIA) guidelines. In 2018, the SEZAD Environmental Regulatory Department developed technical advice on: Air Quality Protection, Biodiversity Protection, Marine Environment Protection, Noise Reduction Protection, Soil Quality Protection and Water Quality Protection. All technical information applies to all branches in the ZEE. SEZAD is involved in the development of an Environmental and Social Management System (ESMS) which is still ongoing and will be strengthened as outlined in the following sections (according to ESAP). SEZAD ESMS will be applicable to all phases of the project life cycle. The Ministry of Environment and Climate Affairs (MECA) is the main agency for regulating environmental and social aspects outside of Special Economic Zones (e.g. removal of offshore sediments or long-range interactions in the marine environment within Masirah Island or species furniture such as birds, whales and turtles).
International and national consultants prepared the environmental and social studies for the sub-projects as listed in Section D of this ESRS. EIAs for sub-projects 1-6 were developed to meet Omani requirements and all sub-projects received the appropriate environmental permits.
The main EIA documents prepared for sub-project 1 describe the environmental mitigation measures to be carried out during construction and include beneficiary-specific management plans, such as the Traffic Management Plan (TMP) and the Environmental Traffic Management Plan (EMP). Within the construction contract, there were variations in the design of internal roads, drainage and utility ditches, and different construction finishes. The preliminary EIA provides comprehensive, high-level information on construction and operational methods and activities for project development, but must also reflect changes to the project. SEZAD has agreed to obtain a written statement from the Contractor showing how construction activities (including modifications) will be managed and monitored in accordance with Omani law.
The documentation provided for sub-project 2 is complete and robust, demonstrating a commitment to monitor and manage the environmental and social performance of the sub-project throughout its useful life. Following the submission of the EIA report, an international consultant prepared several additional studies and assessments, including sampling and analysis of marine sediments, modeling of the plume spread of the offshore well and landfill, and modeling of oil spills.
Based on the documentation of sub-project 3,tThe EIA report details construction methods and activities, types and quantities of machinery and equipment, and resources required during the construction of the project in accordance with Omani law.
For sub-projects 4 and 5, the EIA reports refer to relevant international laws and guidelines. They give an overview of the necessary construction and operational work, in detail it is mainly about the design of dams, canals and drainage systems. Due to the nature of the sub-projects, operational work will be minimal and related to routine maintenance. Quality control plans were developed by the contractor building the Saay and Jurf Dams and the contractor building the Jurf and Saay Canals. These quality control plans generally conform to international dam building and construction practices.
For sub-project 6, the EIA documentation takes into account important environmental receptors, including soil and groundwater, ecology, air quality, noise and climate change. A combination of project-specific survey data and existing survey data and information was used to inform the environmental base. The EIA only focuses on sub-project activities. Several of the sub-project components such as the Duqm refinery and other industrial pipelines, instrumentation, leak detection and fire suppression systems, pipeline operations were included in the refinery's EIA.
SEZAD explained that the operational sub-project 7 does not require an EIA according to national requirements. The contractor for this sub-project 7 has prepared an environmental impact matrix and HSE plan. SEZAD is also committed to providing environmental and social documentation related to the operational phase to identify potential impacts, mitigation and monitoring and provide possible recommendations.
Based on the refinery's Phase 3 IESC-ESDD report and the refinery's ESAP developed for creditors (Lender ESAP), the refinery is substantially in compliance with the requirements of the WBG Environmental, Health and Safety Performance Standards and Guidelines.
DRPIC developed a Cumulative Impact Assessment (CIA) study, Consolidated Environmental and Social Impact Assessment (ESIA), Associated Facilities Management Plan and Cumulative Impact Management Plan for the refinery project to identify and assess third party impacts. Recognize these studiesby SezadExport pipeline corridor (sub-project 6), Duqm export terminal wharf (sub-project 2) and solid product transportation road from refinery to Duqm export terminal as associated facilities (AF) for the project. In addition, the DRPIC communicated with operators in all AFs about the DRPIC's obligations to meet creditors' environmental and social requirements. This included confirming with relevant third party operators that their facilities constituted an AF for the refinery and that it was DRPIC's duty to influence its operators to manage their environmental and social risks as much as possible.
SEZAD plans to develop a long-term environmental strategy for SEZ. To address the potential environmental and social impacts associated with the overall development of the EEZ, SEZAD agreed to a framework for the scope of the Cumulative Impact Assessment (CIA), the methodology, the types of monitoring, the requirements for new tenants and the resources needed to do so to develop perform it. Abroad (according to ESAP). SEZAD will also gather information and data from existing studies (e.g. CIA Port, CIA Refinery, Master Plans) to identify impact trends and change its approach to adaptively change the environmental and social aspects of the EEZ over time manage (according to ESAP). ).
Management program:
The creation of a Construction Environmental Management Plan (CEMP) and SMS plans for some sub-projects and the follow-up prior to the creation of a full EIA (e.g. Project 1) lays a positive and proactive approach to assessing and managing environmental and social risks vicinity . and impacts during construction. When CEMPs were not available, SEZAD agreed to gather evidence that sub-projects complied with Omani law (as per ESAP).
In accordance with the ESAP regarding the operational phase, SEZAD will develop operational and maintenance manuals (O&M) for the projects under the responsibility of SEZAD (sub-project 3, 4, 5), which also cover the management and monitoring of environmental and social measures. For the projects operated and maintained by concessionaires (ie sub-projects 1, 2 and 6), SEZAD oversees the implementation of the O&M manuals. SEZAD will also require all operators/owners to “design” and develop detailed decommissioning plans (ie construction sites, labor camps, quarries, landfills, transport maintenance workshops, etc.).
Organizational capacity and training:SEZAD's Environmental Regulatory Department (ERD) employs 11 people in four departments: 1) Environmental Review and Permissions, 2) Environmental Monitoring and Pollution Prevention, 3) Environmental Inspection, and 4) Hazardous Materials and Waste Management. SEZAD indicated that as part of its resource planning to adapt to the expected growth of SEZ, more specialists will be hired under the ERD and SEZAD will develop and identify a staffing plan and training needs based on best practices, resources and international budgets (as per ESAP). . . These efforts include designating a focal point to coordinate joint environmental and social actions with the refinery and other tenants (per ESAP). In addition to existing HSE expertise, Tatweer will also allocate internal resources to monitor environmental and social issues.
Emergency Preparedness and Response:
On-site visits revealed that contingency arrangements for sub-projects under MIGA are in place in accordance with the requirements of Omani law (e.g. Ministerial Decision 286/2008, Occupational Safety and Health Regulations for Establishments Subject to Employment Law). SEZAD ensures that all six sub-projects have formal emergency plans (ERP) up to date at the construction stage or that contractors provide a written description of how emergencies will be handled, addressed and resolved.
The Sultanate of Oman strengthened its state emergency system after Cyclone Gonu in 2007. There are two laws governing emergency management: the Civil Defense Law (RD 76/1991) and the State of Emergency Law outlined by RD 75/2008. Based on these requirements, SEZAD has developed an Emergency Response Plan (ERP) for the SEZ (Department of Health and Safety, September 2017) and will update it according to PS to cover all seven sub-projects (including the information on how the sub-projects proceed). emergency measures) and the latest developments in the EEZ (according to ESAP).
The PDC contingency plan includes an oil spill plan, roles and responsibilities, and a list of equipment to be installed on site (booms, transfer pumps, high-pressure cleaners, collapsible tanks, etc.); The plan will be updated to reflect changes in activities and developments. DRPIC has an ERP implemented that meets the lender's environmental and social requirements and performance standards.
Follow-up and Verification:
In accordance with SEZAD's mandate as regulator, specialists from SEZAD's Department of Environmental Regulation conduct regular visits to monitor the environmental performance of the site. Environmental reports issued by SEZAD directly to contractors describe violations and propose corrective actions with reference to Omani law. EIA studies describe monitoring requirements for sub-projects within the framework of MIGA. SEZAD will review its health, safety and environmental (HSE) and social inspection program at contractor sites, including construction sites, worker housing and engineering workshops. SEZAD monitors the implementation of the agreed methodology for sub-project 3 with the contractor and carries out environmental and social monitoring for sub-project 1 in accordance with Omani law (according to ESAP). According to the Memorandum of Understanding regulated by RD79/2013, SEZAD sends MECA environmental monitoring information according to international environmental conventions and reports every six months on issues such as greenhouse gases, chemicals, etc.
During the remainder of construction and operation, SEZAD will provide MIGA with regular monitoring reports on the project's environmental and social compliance with performance standards.
Participation of interested parties:
There is a complaints handling page on the SEZAD website. The Grievance Redress Mechanism (GRM) is a task of the Alliances and Development department as part of SEZAD's Corporate Social Responsibility. Interested parties can contact SEZAD by phone call, email, official letters or submit the application form through the web portal. This Grievance Mechanism (GRM) cannot be used in relation to housing and land acquisition matters as such matters are managed directly by the Ministry of Housing (see PS5 for more details). SEZAD will update its existing GRM for affected communities according to PS1 (according to ESAP).
For the refinery project, IESC refinery is considering the robust stakeholder engagement plan and activities to engage all interested or affected parties. The stakeholder engagement plan provides details of the stakeholder GRM, which conforms to international standards and is available to anyone affected by the project or other community members.
PDC developed a Stakeholder Engagement Plan (SEP) in 2016 as part of its Phase 1 Port Operations ESIA. Stakeholders were identified and a summary of engagement was included. In line with best practice, the port has established a complaints mechanism and includes a process for handling anonymous complaints.
SEZAD formalizes your SEP according to the requirements of the PS (according to ESAP). The SEP will cover the ongoing construction and future operational phases of the project.
Complaints mechanism and external communication: SEZAD will publish non-technical summaries of sub-projects on the SEZAD website. SEZAD will implement and maintain a procedure for external communication according to PS1 (according to ESAP). SEZAD is working on its project-level grievance mechanism and recognizes that the efforts will help SEZAD put in place improved practices for managing the environmental and social aspects of its long-term investment program. SEZAD will update its existing grievance mechanism (GM) for affected communities under PS1 (under ESAP). The GM records all safety-related complaints.
Identification of other risks and impacts:
Risks related to climate change could have potential impacts on operations in the EEZ, which could lead to higher operation and maintenance costs. As part of the due diligence of the sub-projects, a high-level climate risk and vulnerability assessment was carried out in accordance with the SEZAD EIA guidelines (2017) and national legislation. Based on available climate change documentation and projections, climate change-related vulnerabilities in the project area include changes in the frequency and intensity of heat waves, dust storms, hurricanes, droughts, sea level rise, ocean, and increases in extreme precipitation events. Climate risks identified specifically for the project could have significant impacts on the performance of infrastructure, public services and activities, including for example: increased damage to the structural integrity of buildings and road surfaces as a result of increased surface flooding, winds and greater temperatures; reduced water quality and soil stability due to increased salinity rates caused by sea level rise and droughts; and increased health and safety risks and decreased productivity as workers are exposed to extreme temperatures.
Measures for resilience to sea level rise have been identified in the design, construction and operation of the project's roads, buildings and equipment. Another resilience feature for EEZ and port development is the construction of flood defense systems, including two flood defense dams and drainage channels as part of the MIGA project. The upstream dams are designed to cushion 1000-year flood events to 100-year flood events, with drainage channels designed to withstand 100-year flood events, significantly mitigating the downstream effects of extreme flooding in the EEZ.
SEZAD committed to conduct a climate risk vulnerability assessment for all seven sub-projects and to examine opportunities to improve resilience across the SEZ (according to ESAP).
PS2: Labor and working conditions
The expected peak workforce during the construction and operation of the entire SEZ is approximately 16,000 projected workers over the next 3 years. Companies in the SEZ have a target of at least 10% Omanization of their permanent workforce during operations. In 2019 there are 1,200 job vacancies in Oman in the ZEE. As of January 2019, SEZ employs approximately 9,500 workers, of which approximately 1,560 are Omanis and approximately 350 are from the Duqm area. Around 3,400 people were employed in the sub-projects of the MIGA guarantee.
Working conditions and industrial relations management
As explained above, SEZAD is a legal body according to RD 119/2011 and SEZAD has developed its internal Human Resources (HR) manual (March 2012). The Human Resources Handbook provides for the establishment of the Human Resources Committee, which oversees decisions on hiring and promotion of staff, training, performance appraisal, etc. Other matters not addressed in the Personnel Handbook may be addressed in separate policies. The Personnel Handbook outlines minimum wage, overtime, termination of employment, sick leave, maternity leave and leave requirements for Omani and non-Omani workers, and according to the document, these two categories have equal opportunities and rights. . The HR manual only covers SEZAD's direct employees. SEZAD has a Code of Ethics and Business Conduct, which emphasizes SEZAD's commitment to ethics and compliance with the law and sets out the rules for ethical and lawful conduct. The SEZAD Code of Ethics and Conduct applies to external contractors and operations. SEZAD (including Tatweer) will review existing Human Resources (HR) policies and recruitment procedures and update the respective policies (not HR manuals enacted by incorporation legislation) that set out the approaches to managing direct employees and enforce the policy for workers hired from third parties . after PS2 (after ESAP).
SEZAD has an Employee Complaints Policy and “Employee Complaints and Remedies” procedure, which outlines the grievances that may be filed for workplace harassment, health and safety, supervisor conduct, and deals with any adverse changes in working conditions. As part of updating SEZAD's HR Policy, SEZAD will review the grievance mechanism in line with PS2 requirements and has agreed to use commercially reasonable efforts to ensure contractors have PS2-aligned grievance mechanisms in place. Where this is not possible, SEZAD extends its grievance mechanism to external contract workers under PS2 (under ESAP).
The SEZAD occupational health and safety standards and standards manual contains the requirements for the work areas of the standards in connection with contractor management. These requirements set the standards for workers' housing, including fire safety, toilets and sanitation, regular cleaning and inspection, interaction with neighboring communities and businesses, and others. Tatweer staff conduct regular site visits using a checklist for inspection of accommodation to ensure compliance with Omani laws.
The 7 sub-projects illustrated different levels of camp organization and living conditions. Most of the camps visited during the due diligence mission had acceptable accommodation, including toilet and washroom facilities, on-site first aid and medical facilities, canteens and cooking facilities, access to potable water and minimal housing. Sub-project 7 was able to provide written evidence (camp audit checklists) that regular camp inspections were carried out. Sub-projects 2 and 6 staff reside in the Renaissance Village, a state-of-the-art residential building being built and managed by a third party to meet the housing needs of the entire SEZ. Some sub-projects did not provide relevant risk assessment and mitigation evidence for worker housing. SEZAD will review its Health, Safety and Environment (HSE) program and social inspections at contractor sites, including construction sites, worker housing and technical workshops (as per ESAP). SEZAD is committed to strengthening its inspection program to ensure reporting and follow-up visits (as per ESAP).
Osh:Through IESC interviews with camp managers, it was found that they were following best practices, in which management cut ties with national and international recruiters who attempt to bill and collect "bails" from workers. Approved recruiters and employers are not legally entitled to charge the worker for his employment (Labour Act 2012, Art. 20). All camps follow best practices of providing workers with their ID cards and copies of passports (ID permits for travel out of Oman and entry into other Gulf countries) and keeping workers' passports (for protection) in camp offices where workers have access to have these documents. , in accordance with Omani law. MD2/2006 issued by the Department of Labor prohibits companies from keeping their employees' passports against the interest of fair labor. Omani Labor Law (RD 35/2003) Article 75 prohibits child or bonded labor and no such incidents were observed in the labor camps visited.
There is a new MD 270/2018 to protect foreign workers leaving their workplace in Oman. Workers have the right to lodge complaints with the Department of Labor and if more than five complaints are received from the same company in one month or ten during the year, the Department of Labor will investigate. If the company fails to comply with the provisions of the Labor Law or the Labor Ordinance, it will be suspended from receiving any services from the Ministry for a period of one year.
Work-and Healthprotection:Omani labor law requires employers to inform workers about the hazards of employment and to provide necessary measures to protect workers from health and machine hazards. SEZAD has a detailed manual of health and safety standards and regulations published in 2018. The manual describes the HSE management system, safety rules, contractor management, emergency preparedness and response, construction sites, labor, analysis of occupational risks, accident reports, inspection forms. , safety talks, etc. SEZAD also has an extensive Human Resources and Social Risk (HRSR) manual. As mentioned above, SEZAD will improve its existing Health, Safety and Environment (HSE) policies and procedures related to a safe and healthy work environment (including food safety), worker accommodation, road safety, incident/accident reporting, root cause analysis, etc. As part of these guidelines, SEZAD will provide clear definitions and expectations of minimum standards that will be reflected in future tender documents. These policies and procedures must comply with PS2 requirements and Omani law (as per ESAP).
Outsourced labor and supply chain:SEZAD has a robust contractor selection process and this process is published on the SEZAD website. Contractor policies are in accordance with Oman's main recruitment and human resources laws. SEZAD (including Tatweer) will extend HSE policy requirements to external contract workers under PS2. All future SEZAD contracts will contain provisions that the contractors' management plans must be aligned with SEZAD's own corporate policies and management plans and these policies must be implemented by all third parties (contractors) associated with SEZAD (according to ESAP). SEZAD will create and implement a supply chain policy according to PS2 (according to ESAP).
PS3: Resource efficiency and pollution prevention
Resource efficiency:
SEZAD's EIA guidelines generally capture the efficient use of resources to be considered in design documents. The EIA documentation describes resource efficiency measures that can be implemented during the construction and operation of the project. There is no evidence or confirmation that such measures have been implemented. SEZAD agreed to create company guidelines and establish minimum standards (e.g. International Good Industry Practices, GIIP) for resource efficiency measures in projects within the SEZ (e.g. in procurement documents, contracts and a technical guide). These relate to reducing the consumption of energy, water and other material resources and inputs (technically and financially feasible and profitable). SEZAD will also ensure that its long-term environmental strategy for the EEZ includes resource efficiency measures that will be integrated into future tenants' operations and maintenance plans and project management plans (as per ESAP).
The EIAs considered alternative methods and activities to reduce greenhouse gas (GHG) emissions. At this stage of the project, it is difficult to estimate the carbon footprint. The EIA reports reflect the commitment to monitor GHG emissions during the construction and operational phases and there is evidence for the GHG calculation in the air quality monitoring reports and in the environmental performance reports (sub-projects 1 and 2). According to ESAP, SEZAD has agreed to take steps to ensure that Projects 3 and 6 are recorded retrospectivelyo Best estimate of construction phase fuel consumption data to meet SEZAD requirements, review of GHG data calculations for projects 4 and 5 and estimate of GHG emissions (for operations) for projects 6 and 7 to estimate the combined GHG Complete a project's carbon footprint. In accordance with national requirements (referring to the IPCC Intergovernmental Panel on Climate Change), SEZAD agreed to develop a GHG methodology and ultimately to produce an overall GHG emission footprint for the EEZ. In the long-term environmental strategy of the SEZ SEZAD will provide guidance on the type of information required by new tenants to report a greenhouse gas footprint (under ESAP).
For the refinery project, the GHG emissions have been estimated and indicate that the project emissions will exceed 100,000 tons CO2eq per year, which will trigger the GHG reporting obligations in the NDs. The Refinery IESC states that the estimate of operational GHG emissions for the refinery is reasonable and sufficient given the current status of project development with some elements of the creditors' ESAP on collection and procedures.
With regard to water efficiency, none of the sub-projects under the umbrella of MIGA considers a large water requirement during construction and operation. Water reuse has been considered in the EIA and Environmental Management Plan (PGA) documents. For the refinery, the IESC recommended that the refinery develop a detailed water balance sheet to cover all phases of the project as part of the lenders' ESAP.
Contamination Prevention:
Construction contamination impacts were identified during the EIA process and reflected in the Construction Environmental Management Plans (CEMP) and contractor HSE plans for all 7 sub-projects. These plans provide details of environmental protection measures to prevent and minimize environmental impact during construction. These measures include dust suppression, secondary containment to prevent spills, timely disposal of construction waste, allocation of space for storage of construction materials. SEZAD prepares company guidelines on pollution prevention according to PS3 and best efforts for projects within the SEZ to reflect these guidelines in e.g. tender documents, contracts and a technical guide. Based on all efforts, SEZAD will also ensure that its long-term environmental strategy for the EEZ takes into account potential health impacts on nearby communities and anti-pollution measures that will be integrated into operations and maintenance plans and environmental management projects for future tenants. (according to ESAP).
The refinery will emit emissions to air and water during construction, pre-commissioning, commissioning and operation. The predicted type, rate, amount and concentration of these discharges were identified in the ESIAs. Based on the Refinery IESC Phase 1 and 2 ESDD recommendations, a revised consolidated ESIA report (CIAMR) and a CIA report were developed and made available for the Refinery IESC review.
The dredging from Sub-Project 2 will be mostly disposed of onshore in accordance with the permit issued by SEZAD and has been used to level PDC areas used for onshore infrastructure development. The permit for offshore dredger disposal is issued by MECA at an existing approved landfill. As part of the CEMP, the contractor has developed a dredger management plan that includes monitoring and management actions. The implementation of this plan is monitored by SEZAD. The dredging is done in accordance with the rates modeled and allowed by MECA.
Currently, most of the waste in the SEZ is sent to the unchanged landfill in the SEZ. An Integrated Waste Treatment and Storage Facility (IWTSF) has been built and will be operational once the commercial terms have been agreed between SEZAD and the operator. The IWTSF includes a storage and transfer point for hazardous waste. Types of waste and disposal and recycling measures are described in some sub-project-specific EIA and EMP documents. SEZAD will carry out a waste audit of the 7 sub-projects and the port to identify types and quantities of hazardous waste generated, transport and final destination (according to ESAP). Waste audit includes verification of waste records, waste transporters, etc. Based on the audit results, SEZAD creates a Waste Management Plan (WMP). This plan will include definitions of each type of waste, confirm roles and responsibilities for waste, establish the need for records and certificates (e.g. waste transport companies), and describe the destinations of each type of waste. The WMP will cover the remainder of the construction phase of the 6 sub-projects and will be relevant to operations and future tenants moving to SEZ lots (as per ESAP).
SEZAD will actively cooperate with Oman Environmental Services Holding Company S.A.O.C. (be'ah) to agree on the timing of the opening of the new IWTSF. When the hIWTSF is operational, SEZAD will record the volumes of waste being transported to that facility and the subsequent transfer from the IWTSF to another be'ah facility. SEZAD will develop a closure plan for the existing unplanned landfill according to PS and GIIP (according to ESAP).
PS4: Community Health, Safety and Security
The sub-projects (and the SEZ) are located in an area sparsely populated by semi-nomads and have the following potential beneficiaries:
- Nafun (9 km from the port area)
- Al Tayari (approx. 7 km from the site of the Renaissance facility - third-party accommodation)
- Duqm Hospital (5.5 km from the port)
- New housing development called "150 Villas" (approx. 9 km from Duqm Airport)
- City of Duqm, about 7 km from the port.
Community Health and Safety:
The initial social situation in the EIAs for the 7 sub-projects consisted of a compilation of previous reports. Household surveys or community consultations were carried out for a sub-project. In order to increase awareness and monitoring of the project-related health and safety impacts in the community, SEZAD agreed to include aspects of risk assessment and health and safety impacts in the operations and maintenance manual (O&M) of the affected communities. SEZAD will use commercially reasonable efforts to include community health and safety guidelines in tender documents and third party contracts (as per ESAP).
Prior to blasting as part of site preparation, the contractor submits their blasting plan for approval by the Royal Omani Police. A safety zone will be established and advance notice will be sent to surrounding communities.
Construction of the seven sub-projects is nearing completion and therefore it is expected that the community health and safety impacts during the operational phase will be primarily associated with additional traffic (heavy vehicles). Potential impacts relate to public safety, emissions, noise and nuisance. SEZAD is committed to developing a Traffic Management Plan (TMP) as part of the ERP, which not only considers how the construction and operational phases of the seven sub-projects affect local traffic (including safety), but also informs about the capacity of the roads, highways and intersections for future planning. The TMP will also describe safety standards (e.g. barriers, lane markings and signage).
According to the building permits, SEZAD requires that all projects comply with the requirements of the Civil Defense and Ambulance Public Authority, which certifies the safety aspects considered in the project.
As mentioned in PS1, climate change projections for the project area indicate that increased climate vulnerabilities may exacerbate climate-related impacts such as increased most likely flood levels and extreme temperature fluctuations, leading to the spread of vector-borne diseases that create unsafe working conditions. SEZAD commits to carry out the above climate risk vulnerability assessment (according to ESAP).
Dam Safety and Emergency Response:The project is located in a seismic zone in a bay where several wadis (i.e. valleys) drain the higher interior plateaux to the sea. Previous studies recommend the construction of at least two dams (Saay and Jurf) and three canals over the project area (ie SEZ) to ensure safe transport of stormwater. As part of a flood protection system, SEZAD is building two flood protection dams (which are part of the seven sub-projects of the MIGA project). The dams were designed to mitigate the 1000-year flood event to the 100-year flood event. Therefore, the outflow from the HWE corresponds to the 100-year flood.
Located upstream from the Jurf and Saay wadis in the mountainous areas around Duqm, these two earthen dams are being built to stem flooding from rare torrential rains. Both flood protection dams are considered large dams. The flood control system also consists of drainage channels within the Jurf and Saay wadi. The canals will be constructed through a combination of excavating the natural surface of the ground and building 3 to 4 meter high earthen embankments.
After the storm, the stored water is released downstream of the dams in a controlled manner through the dam's bottom outflow and discharged into the sea. If there is no storm, flood protection dams are dry.
The IESC review confirmed that the guidelines used for the design of flood control dams were in line with good international practice. The quality assurance plans for the Saay and Jurf dams and canals (sub-projects 4 and 5) essentially correspond to international practice for dam technology and construction.
Although the communities do not live immediately downstream of the flood control levee, there is or will be significant infrastructure and manpower. Dam failure analyzes were performed on both dams and are described in the detailed design reports prepared for both dams. Sunny day (pipe rupture) and Probable Maximum Flood (spillway rupture) analyzes were performed for the Jurf and Saay dams. The results of the dam failure analysis were used to develop underwater dam failure flood maps for 'probable maximum flooding'. The dam failure analysis for a sunny day poses no threat to the community downstream. SEZAD is preparing an Emergency Response Plan (EAP) for the assets, including flood maps developed from the results of dam failure analysis (per ESAP).
As part of the PS3-related ESAP commitments, SEZAD has committed to developing a checklist of general compliance monitoring points covering management of hazardous materials. As part of the Waste Management Plan, SEZAD will include procedures to identify appropriate transport routes for hazardous materials and waste within the EEZ. SEZAD will develop a closure plan for the existing unplanned landfill according to PS and GIIP (according to ESAP). SEZAD is also responsible for the expansion and improvement of public services in the region directly or indirectly (energy and drinking water) and in relation to municipal services (IWTF).
As part of the development and implementation of environmental and social management and HSE plans (e.g. environmental monitoring, emergency plans), SEZAD produces a map of sensitive natural and human receptors (according to ESAP).
Activities at SEZ employed around 9,500 people as of January 2019, 83% of whom are expatriates. Although the majority of the sub-project's workforce lives in workers' accommodation, there is an opportunity for workers to interact with local communities and communities. Sub-projects have PR officers (usually local) to communicate with local communities who can raise concerns and complement SEZAD's stakeholder engagement activities. SEZAD and Public Information Officers meet regularly to discuss concerns raised, including possible implications related to the influx. As the development of the SEZ is at an early stage and the workforce is expected to increase significantly, the SEZAD, as part of the ERP, will take into account the capacity of local rescue service providers and healthcare facilities (as per ESAP).
As mentioned above, the SEZAD Code of Business Conduct and Ethics applies to all employees, consultants, contractors, suppliers, investors and anyone who represents SEZAD in its business operations. Briefly describe the substance abuse policy and ask staff to respect the culture of the local communities. The common communication channel specified in the document is reporting to the direct superior. As mentioned above, SEZAD will use commercially reasonable efforts to include guidelines for community health and safety aspects in tender documents and contracts with third parties. These aspects include provisions for future inflows of workers and management of such impacts.
SEZAD is committed to ensuring that the ESMS includes requirements for third parties to address the potential for community exposure to waterborne, waste-borne and vector-based diseases resulting from operations and potential communicable diseases associated with the influx of or can, prevent and minimize permanent employees. Project work (according to ESAP). For sub-projects 1, 3 and 7, SEZAD will also describe community health and safety standards (e.g. barriers, traffic signs/markings and signage).
security personnel:
Most of the EEZ is accessible except key strategic locations which are fenced with controlled access points (e.g. Customs and Inspection Area (Sub-Project 1), Port). Although not yet built, the refinery will be fenced off with controlled access. Other security measures include closed circuit television (CCTV) cameras and routine patrols. Within the SEZ itself there will be a Royal Oman Police (ROP) post in the Port Customs and Inspection area. There is an existing full-service regional ROP station within the boundaries of the SEZ.
Given the strategic importance of the project and the nature of the activities, public security forces (e.g. Royal Omani Police, Omani Coast Guard, etc.) ensure the security of the SEZ (as well as certain projects within the SEZ). Contracted private security is also used by investors and contractors. As reflected in the PAAS, SEZAD is committed to conducting a security risk assessment that recognizes SEZAD's PS4 responsibilities. The results of this assessment will be addressed in a security management plan for the SEZ, which is compliant with PS4 requirements (according to ESAP). SEZAD's grievance mechanism is being revised to address security concerns.
PS5: land acquisition and forced resettlement
In the past, the area being developed for the SEZ has supported a limited population in small, scattered settlements. Recipients include people seasonally occupying the few local temporary residences and fishermen along the beach and by the sea.
Under RD85/2006, the Duqm area was designated as a public good. The GoO identified all owners and their potentially affected assets in 2007 through inventory and satellite imagery for the entire area except for the villages of Al Shuwayr and Nafun. All property owners were compensated in cash by the Ministry of Regional Municipalities and Water Resources. The Ministry of Housing compensated landowners in Nafun and Al Tayari areas for the land. The GoO allocated 16 million Omani rials (about US$41.6 million) to build 150 houses for the affected people and in 2012 SEZAD was commissioned to oversee the completion of this construction. RD44/2014 highlighted the public utility of some lands where private ownership was accredited in the region, in addition to an area of 15 km2 earmarked for urbanization and compensation so that those affected could continue to own their land. In 2014, SEZAD, in coordination with the Ministry of Housing, commissioned a consultancy to conduct an additional study on the village of Nafun and Al Shuwayr in order to update the basic conditions. The survey results were provided to the Ministry of Housing and respective departments to make executive decisions for each household in Nafun (there was no change to the Al Shuwayr baseline). MD61/2017 was set up to form a mixed commission composed of SEZAD and the Ministries of Interior, Municipalities, Housing and Social Development to identify the names of those affected who are entitled to the 150 vilas. This working group decided to extend the baseline survey to the entire EEZ including Saay, Nafun, Al Tayari. In December 2018, the task force released the names of those affected and gave a month to appeal. The Ministry of Housing is now examining the resources.
The GoO has commissioned a new development of modern homes (150 villas) within the EEZ. Each affected household will receive a new replacement house/villa of approx. 400 m2 with six en-suite bedrooms. The resettled population is expected to benefit from the ZEE in terms of roads, public services, jobs, etc. provided in the area. In addition, fishermen will benefit from the use of the new fishing port and fishing industrial complex funded by the GoO, increasing income levels and living standards.
SEZAD has no direct responsibilities under PS5 as resettlement or compensation to local communities was managed by the GoO (specifically the Ministry of Housing) when the planning and construction process for the port and SEZ under RD 44/2014 started. The project area for the seven sub-projects consists of completely undeveloped desert land or parcels earmarked for industrial development, with no residential lots or community facilities in the immediate vicinity. However, the historic process of land acquisition that the GoO began prior to the formation of SEZAD is ongoing and may have adverse effects on the communities and people who use the land. As part of the government-led resettlement, SEZAD has agreed to take the following actions (under ESAP):
- Work with relevant government agencies to identify roles and responsibilities under RD 44/2015 and outline stakeholder engagement to address the situation of affected parties.
- Develop and implement a program, in consultation with the GoO, to define appropriate practical actions to support resolution of historical and ongoing impacts on affected parties; j
- Make your grievance mechanism available to affected parties and publicize it.
For any potential future land acquisition, SEZAD agreed to develop a land acquisition framework in line with national requirements and PS5 before embarking on such activities (under ESAP).
With regard to the resettlement of the refinery, DRPIC as was assigned a specific locationdesignated location for the project. The refinery has expanded its grievance mechanism to include resettlement-related issues, for example construction supervision is already included in the grievance mechanism for the construction phase and in the Health, Safety and Environment and Social Guarantee plan and plan/program of social supervision and health. The refinery IESC recommended that the DRPIC establish a monitoring program (as part of the ESMP) of its grievance mechanism for issues related to the resettlement process, livelihood impacts and cultural land use within the refinery area during the refinery phase.
PS6: Conservation of Biodiversity and Sustainable Management of Living Natural Resources
Much of the land in the SEZ is dominated by degraded or converted sand/gravel plains, with a variety of habitats ranging from sabkha (salt pans) with tidal mud and sand, mountains, outcrops, plateaus and slopes to wadis and channels. .The SEZ footprint overlaps with two Important Bird Areas (IBAs): Jiddat al Harisis and Ad Duqm. According to the Phase 1 Port Operations EIA, essentially all birds in Ad Duqm are migratory and none (except for a few larks) use the area as a breeding ground. The importance of Ad Duqm, as well as Bar Al Hikman to the north and Khwar Ghawi (both outside the EEZ and catchment area boundaries) to the south, lies in their value as stopping points during spring and autumn migration – overflights of migratory birds from Central Asia) and as wintering grounds .
These IBAs are likely to contain critical habitat for certain birds and other species as defined in PS6. Sub-projects 4 and 5 overlap a small area of the Al Wusta Wildlife Reserve. This reserve was formerly referred to as the Arabian Oryx Sanctuary established by RD 4/1994 and previously classified as a World Heritage Site by UNESCO for its geological, ecological and cultural importance. The site was removed from the UNESCO World Heritage List in 2007 after the threshold was lowered by 90%. Permission for sub-project 5 was granted by MECA as the site is outside the EEZ boundaries. In consultation with the Environmental Conservation Office at Royal Court Diwan, a clearance has been issued to proceed with construction.
As part of the studies for Phase 1 of the Environmental Impact Assessment for Port Operations, sixteen species of marine mammals were recorded in the Gulf of Masrah, including the endangered humpback whale, other baleen and toothed whales and dolphins. Sea turtles, particularly the critically endangered green sea turtle and critically endangered loggerhead sea turtle, are also common in the area as they forage and nest in the offshore waters. Data from tagged sea turtles indicates that the Gulf of Masirah is known to be on the migratory route for all species of sea turtles nesting in Oman. Studies for Phase 1 Port EIA operations identified 39 plant species, 5 of which are on the Oman Red Plant List; Many tracks were observed in the study area, with IUCN near threatened species of striped hyena tracks and the IUCN endangered species Egyptian spiny-tailed lizard.
Examples of mitigation measures to minimize impacts on wildlife include developing buffer zones, minimizing light and noise pollution, supporting conservation programs, reporting large wildlife sightings, implementing waste management, controlling invasive species, and planting native species.
The DRPIC conducted a comprehensive biodiversity assessment, which is detailed in the Biodiversity Assessment Report and in the biodiversity sections of the Consolidated Impact Assessment and Mitigation Report. The Refinery IESC considers both reports to be of high quality as they represent a harmonized habitat map that combines design and AF data into a single habitat map and provides clear reference descriptions and impact assessments for habitats, birds, mammals, reptiles and floral species. SEZAD aims to build on this work to further develop it as relevant to the ZEE.
Among the extremely serious risks, the DRPIC Biodiversity Assessment primarily identifies the impacts of their AFs, such as the potential risk of an oil spill at Raz Markaz, ship collisions with species of cetaceans and sea turtles, and the adverse impact of factory shipping at the export terminal at Duqm IBA. The assessment proposes the formation of an "advisory board" to guide containment and surveillance by linking industry (with) government, conservation and research interests. To mitigate the impact on the Duqm IBA, the report proposes increasing the remaining area of the IBA through the creation of built-up wetlands through dredging and off-site mitigation.
DRPIC has developed a biodiversity offset framework that the Refinery IESC believes is complete and satisfactory for PS6. However, they suggest that a summary of the offsetting strategy should be developed as a precursor to the Biodiversity Action Plan (BAP), which identifies offsets related to, and not directly related to, refinery impacts and outlines the role and responsibilities of the DRPIC and identifies options and offsets sets out proposed actions to offset the impact on the two IBAs. However, the Refinery IESC recognizes that the implementation will not be entirely under the control of the DRPICs. After the Biodiversity Offsets Strategy (BOS) Report has been developed, the necessary offsets need to be further developed and implemented through the development of BAPs.
According to ESAP, SEZAD, in coordination with other ZEE entities, will quantify and assess the impacts on natural habitats related to each sub-project to include a Critical Habitat Assessment (CHA) covering the following key groups: cetaceans; turtles; endemic plants; rare/endangered reptile species; Duqm IBA/Migratory Wetland Birds; Jiddat al Harisis IBA; and the Al Wusta Wildlife Reserve. The requirement for a CHA may be based on extensive biodiversity work prepared by others. SEZAD will continuously coordinate with the refinery and port in the development of its biodiversity offset framework/strategy and action plan on biodiversity to reflect its own approach to biodiversity and to offset the impacts of the seven sub-projects. SEZAD will identify the creation/compensation of appropriate compensatory habitats to meet zero net loss (natural habitats)/net gain (critical habitats) requirements.
SEZAD is committed to:
- In relation to natural and critical habitats, carry out a cumulative impact assessment (CIA) considering the seven sub-projects, associated facilities (AF) and other planned developments in the SEZ in Duqm, or ensure that this is done as part of the recommended by the Work involved is CIA. on PS1 above.
- For sub-projects 4 and 5, ask the contractor to explain how measures have been taken to minimize work areas near the Oryx reserve and dust suppression in areas within and adjacent to vegetation.
- Require sub-projects 6 and 7 contractors to confirm their approach to managing and monitoring environmental mitigation actions in a written statement.
SEZAD either conducts an ecosystem services assessment for all sub-projects or conducts a "cross-project" assessment where all projects are considered together (according to ESAP). In support of its long-term environmental strategy, SEZAD will adopt a procedure or clause outlining its approach to biodiversity for future projects that will consider a supply chain assessment for all contractors and operators, while respecting Oman's commitment under international agreements and conventions ( according to ESAP ) .
PS8: Cultural Heritage
RD 6/1980 of the National Monument Protection Law refers to RD 12/1976 and 14/1976 on the establishment of the Ministry of Heritage and Culture. RD 6/1980 clarifies several articles on the protection of elements of cultural heritage, prohibiting individuals or owners of cultural heritage from destroying or adversely affecting these resources and adjacent properties. It also describes, during construction and excavation work, the procedures related to accidental finds that must be reported to SEZAD, which informs the Ministry of Heritage and Culture.
The final master plan and development framework for the SEZ (Atkins, May 2018) indicates a large number of archaeological sites in the areas to be developed as part of the SEZ area. SEZAD has agreed to develop a random determination procedure to submit to the SEZ and will publish it on its website (pursuant to ESAP) to complement existing practices. Through the SEZAD website, contractors report chance finds using the chance find registration form. Contractors should use the form if there is a suspicion that artifacts will be found. The proposed approach for the removal, relocation, maintenance and protection of all archaeological sites within Duqm is to be discussed and agreed with SEZAD.
The areas in and around the seven sub-project sites and workers' housing visited during due diligence have seen significant development. The contractors followed the CEMP and Cultural Heritage Preservation Procedures under Omani law.