Globeleq Menengai

MIGA has been requested to provide guarantees covering Equity and Quasi-Equity investments from Globeleq Geothermal (Kenya) Limited of the United Kingdom (referred to as “Globeleq” or the “sponsor” throughout the paper) to the Menengai geothermal power plant (the “Project”) for a duration of up to 20 years. Further information on the proposed MIGA guarantee is available in the Summary of Proposed Guarantee.  

The Menengai Project consists of a 35 megawatt (MW) greenfield geothermal power plant, and civil, electrical, and mechanical works including 11/132 kilovolt (kV) step up transformers, interconnection, and other associated infrastructure. The Project will be developed by Globeleq Menengai Geothermal Limited (“GML”) - the Project Enterprise (“PE”).   

The Project is located in the Menengai geothermal field in Nakuru County, about 180 kilometer (km) north-west of Nairobi, at the outskirts of the town of Nakuru. Menengai is a large caldera volcano on the floor of the Rift Valley.   

The plant will receive all its geothermal steam from the Geothermal Development Company (GDC), a Kenyan government entity tasked with providing steam and related facilities to geothermal projects in Kenya. At the geothermal field, three 35 MW geothermal power plants will be developed: (i) Sosian Geothermal Power Station, operational since 2023 (ii) GML Geothermal power station (the Project); and (iii) Orpower22, under development. GDC will sell the steam to all these three power plants. Sosian, GML and Orpower22constitute phase 1 of the development of the Menengai geothermal potential. GDC intends to develop up to 500 MW geothermal power in the next 20 years in phases 2 and 3. 

The steam for the Project will be sourced from nearby wells and supplied to the plant. The (production & injection) wells, separators and transport pipes as well as the water pipes to the Project are part of GDC’s facilities. The (production & injection) wells, separators, transport and water pipes are considered associated facilities to the Project.  

A 132 kilovolt (kV) on-site substation and a 13km double circuit 132kV line from Menengai to Soilo substation have been constructed and energized by the Kenya Electricity Transmission Company (KETRACO) and are ready for connection. The substation and the 13 km 132 kV transmission line will be operated by KETRACO and are considered associated facilities to the Project. 

The Engineering Procurement Construction (EPC) contractor was awarded to Toyota Tsusho Corporation (TTC) and their local subsidiary CFAO Kenya Limited. Construction started in January 2024. There are about 90 persons working on site, clearing, escalating, and leveling the project site, and the construction of offices and foundations. The construction is scheduled to last 23 months, with operations expected to start in December 2025. The Operation and Maintenance (O&M) activities will be performed by Globeleq from commercial operations date (COD) onwards.  

Globeleq is an existing MIGA client. MIGA has three existing portfolio projects owned by Globeleq: (i) Kribi power plant, a 216 MW gas-fired (diesel backup) power plant located in Mpolongwe, Cameroon; (ii) Dibamba power plant, a 86 MW heavy fuel oil power plant located in Douala region of Cameroon; (iii) Central Térmica de Temane (CTT) in Mozambique. These projects are regularly monitored by MIGA, and to date the environmental and social (E&S) performance has been satisfactory. 

MIGA’s due diligence review considered the E&S management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and, in the E&S Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards. Key E&S issues associated with the Project business activities are summarized in the paragraphs that follow. 

PS1:  Assessment and Management of Environmental and Social Risks and Impacts 

Environmental and Social Assessment and Management System: The Project sponsor, Globeleq, has developed an integrated management system (‘IMS’) that covers health, safety, environment, security and social (‘HSESS’) aspects. The IMS describes the system by which HSESS risks are managed and articulates the organizational requirements to implement the management system across the Globeleq portfolio for both project development and operations, including the Project. The HSESS IMS is supported by forms and templates for its implementation (e.g. permit matrix, legislation register, document register, incident reporting form, training matrix, audit and inspection protocols). All Project employees and contractors are required to adhere to Globeleq’s IMS. At the Project level, GML has developed and is implementing an HSESS Construction Management Plan (CMP) in line with Globeleq’s IMS. 

Policy: Globeleq has a corporate HSESS policy which describes its commitment to the protection of the environment and people, and the safety of its employees. The policy requires compliance with applicable laws and relevant health, safety and environmental standards. GML has developed a Project specific HSESS Policy in line with Globeleq’s corporate HSESS policy. 

Identification of Risks and Impacts: An initial Environmental and Social Impact Assessment (ESIA) was undertaken by GDC for the three anticipated power plants at the Menengai Caldera in 2012. Based on a gap analysis, a bankable ESIA for the Project was carried out in 2015 supplemented by specialist air quality and aquifer studies to update previous studies undertaken by GDC. In addition to the ESIA, the Project HSESS CMP includes an E&S mitigation register that considers the impacts identified in the ESIA and the proposed mitigation measures. 

The 2012 ESIA prepared on behalf of GDC covering the three anticipated power plants includes a cumulative impact assessment. According to the ESIA prepared for GDC, the cumulative impacts range from minor to moderate and can be mitigated. The following moderate cumulative impacts were identified: (i) Greenhouse gases and hydrogen sulfide (H2S) gas emissions, (ii) vegetation clearance and habitat degradation, (iii) impact on water resources due to water abstraction and contamination of underground and surface water bodies. GML has supported the establishment of  a Health, Safety and Environment (HSE) committee made up of GDC and the other independent power producers (IPPs) (currently Sosian and GML  and eventually Orpower22 when activities start). From GML’s side the Health and Safety (H&S) manager and Environment, Social, Governance (ESG) manager are part of the committee as well as two other nominees from the EPC side. The committee meets on a quarterly basis and the objective is to promote collaboration on E&S issues, including managing of cumulative impacts. In addition, the Project’s air quality management and monitoring plan takes into account cumulative impacts from different actors such as IPPs and GDC. 

Measures to prevent gender-based violence (GBV) and sexual exploitation, abuse and harassment (SEAH) have been incorporated into relevant management plans and procedures by both the PE and the EPC contract to manage the risk of GBV/ SEAH in communities surrounding the Project, and in the workplace within the construction site.  

Management Programs: Project specific management sub-plans have been developed to support the health, safety, environment, security and social construction management plan (HSESS CMP). The management sub-plans define the Project’s desired outcomes and actions to address the issues raised in the risks and impacts identification process. The HSESS CMP and supporting sub-plans are consisted with Good International Industry Practice (GIIP), the performance standards and relevant WBG EHS Guidelines.  

The HSESS CMP sub-plans include: (i) emergency preparedness and response, (ii) community health, safety and security, (iii) traffic and transportation, (iv) site clearance and rehabilitation; (v) water resource management; (vi) waste management; (vii) pollution prevention and control sub-plan (addressing noise, dust, management of hazardous materials and effluent discharges); (viii) cultural heritage sub-plan (incl. chance finds procedure); (ix) biodiversity management sub-plan; (x) facilities and workers Accommodation sub-plan (including pest management). Occupational health and safety is incorporated in the HSESS CMP. Other supporting plans include: (i) Socio-Economic Development Plan / Community Development Plan, (ii) Community Engagement Plan, and Stakeholder Engagement Plan including Community Grievance Mechanism (GM) (including Terms of Reference for Project Stakeholder Committee). The HSESS CMP and sub-plans include several templates and trackers to assist with the implementation of the Project HSESS IMS requirements. The EPC contractor has developed and is implementing a Construction Health, Safety and Environment management plan (C- HSEMP) in line with the HSESS CMP and supporting sub-plans. GML will develop and/ or update and/ or finalize and implement an integrated management system for the (O&M) phase in line with Globeleq’s IMS (ESAP #1). 

Organizational Capacity and Competency: GML has developed an organizational structure for the Project that defines roles, responsibilities, and authority to implement E&S requirements with clear lines of responsibility and authority designated. Key E&S staff appointed include: (i) Environment, social and governance (ESG) manager responsible for the implementation of the HSESS-CMP requirements; (ii) ESG/ Community Liaison (CLO) officer whose key function is to monitor day-to-day implementation of the contractor HSEMP, liaise with GDC counter parts, implement Stakeholder engagement plan, address grievances, monitor and report performance against key performance indicators (KPIs); and (iii) Health, Safety and Security (H&S) manager who among others will monitor compliance of the EPC contractor health and safety performance against applicable KPIs. Additional support to the Project team is available from Globeleq’s corporate ESG team. The EPC contractor also has a site based HSE officer overseeing E&S performance of construction activities in collaboration with GML’s team. 

Emergency Preparedness and Response: Complementing the HSESS CMP, an emergency preparedness and response plan (EPRP) has been developed which sets the Project’s requirement for the EPC contractor to establish a Project EPRP. The EPC contractor’s EPRP considers risks related to medical and fire emergency, severe weather, earthquake, environmental emergency, armed robbery/ attack on site and accidental release of H2S and others. The EPRP also contains provisions related to training and drills and evacuation. GML will review and update the EPRP for operations and will include detailed procedures for H2S incidents including community responsibilities and actions when H2S emergencies occur and facilitate community participation in H2S drills and in emergencies (ESAP #1).  

Monitoring and Review: E&S monitoring has been incorporated in the sub-plans as part of the HSESS CMP and in the EPC’s C-HSEMP. In addition, during construction both GML and the EPC contractor are responsible for day-to-day monitoring. During construction semi-annual monitoring reports will be shared with MIGA and during operations the Project will be required to submit annual E&S monitoring reports to MIGA. Independent monitoring of environment, health and safety, labor and social aspects of construction activities will be undertaken quarterly during construction. 

Stakeholder Engagement, External Communication, and Ongoing Reporting to Affected Communities: During the 2015 ESIA update study, eight general public meetings were held at sub location levels within the project area as well as key informant interviews with civil government agencies and other institutions and household surveys. In addition, GML has developed and is implementing a Stakeholders’ Engagement Plan (SEP) that considered continuous involvement of the identified stakeholders in project construction and operation phases. Stakeholder consultations in preparation for the start of construction were undertaken by GML in February 2024 prior to the start of construction activities. Communities surrounding the Project are regularly informed of Project progress through the activities listed in the SEP. 

Grievance Mechanisms: A Grievance Redress Mechanism (GRM) has been prepared and is being implemented as part of HSESS CMP. Surrounding communities are aware of the GRM and how to raise grievances. The GRM will be updated for the operations phase (ESAP #1). 

PS2:  Labor and Working Conditions 

The Project is expected to employ approximately 350 workers at peak construction. Majority of the workers will be Kenyan nationals employed by the EPC contractor. A limited number of expatriate staff will be retained for project management and specialized construction related work. Whilst qualified local community members will be prioritized for employment opportunities, it is expected that required workforce will also be sourced from outside the project area. Up to approximately 30 workers will be employed during the O&M phase of the project.  

Human Resources (HR) Policies and Procedures: As part of the project documentation, GML has developed a labor management plan (LMP) which articulates the Project’s commitments to labor and working conditions and sets out minimum requirements on labor management for the construction and operations phase, including i) a worker code of conduct, ii) recruitment, iii) local content, iv) induction, v) worker disciplinary management, vi) grievance management, vii) GBV/SEAH. Guided by the requirements defined in the LPM and consistent with national legislation and PS 2, the EPC contractor has developed HR policies and procedures supplemented by a Site LMP. GML conducts regular audits of the EPC contractor’s LMP requirements and will report the findings of the audit to MIGA as part of the Annual Monitoring Report.  

Working Conditions and Terms of Employment: The EPC’s site LMP includes a contract of employment template that presents working conditions and terms of employment and defines: (i) remuneration; (ii) working hours; (iii) leave requirements; (iv) medical assistance and others. The site LPM also includes the right of workers to join trade unions. All workers receive a written contract of employment. Workers will reside offsite, in Nakuru town or in adjoining community areas.  

Non-discrimination and Equal Opportunity:  The GML’s and the EPC’s site LMPs include provisions to promote the fair-treatment, non-discrimination, and equal opportunity of workers. The LPMs state the Project’s commitment to the principles of non-discrimination, equal opportunity and fair treatment in the workplace in accordance with the requirements of national legislation and PS 2. As such the Project commits to not base employment decisions on personal characteristics such as gender, race, nationality, religion, age, HIV status, sexual orientation or disability.  

Grievance Mechanism: The GML’s and the EPC’s site LMPs includes a worker’s grievance redress mechanism (GRM). The GRM applies to all project workers including those employed by sub-contractors. The GRM is made readily accessible and communicated at induction and through notice boards. The GRM includes information on how to handle complaints involving GBV/ SEAH such as respecting confidentially and having a female point of contact receiving GBV/SEAH grievances. 

Child and Forced labor: The GML’s and the EPC’s site LMPs clearly indicate that the minimum age of employment for the Project is 18 years of age. In addition, the LMPs includes mitigation measures to prevent forced labor/ bonded labor on site and in primary supply chain.  The LMPs also includes measures related to GBV and SEAH including worker and GBV/SEAH code of conduct.  

Occupational Health and Safety (OHS): The activities undertaken for any construction project present inherent health and safety (H&S) hazards. Consideration of occupational health and safety (OHS) is incorporated into GML’s CMP. To address OHS risks, GML commits to provide a safe and healthy working environment, defining the OHS requirements to be implemented by the EPC contractor. The EPC contractor has developed a Project-specific OHS management plan. GML will develop an OHS management plan for O&M which will address the common risks associated with geothermal plant operations such as exposure to geothermal gases, heat, confined spaces, noise and other (ESAP #1). 

Workers Engaged by Third Parties: Per GML’s LMP, the EPC contractor will require its sub-contractors to develop and implement workplace rules, processes, and procedures in line with the EPC’s human resources, OHS and environmental policies and procedures.  

Supply Chain: GML’s LMP also includes supply chain management to identify primary suppliers and ensure that OHS and other labor requirements (i.e. minimum age of employment, no forced labor) are cascaded to the primary supply chain.   

PS3:  Resource Efficiency and Pollution Prevention 

Resource Efficiency 

Greenhouse Gases (GHG): The Project GHG emissions are expected to be more than 25,000 tCO2e/year. GHG emissions accounting will be undertaken on an annual basis and provided to MIGA as part of the Annual Monitoring Report. Mitigation measures for GHG emissions during the construction stage have been included in a pollution prevention and control plan and traffic & transport management plan. 

Water Consumption: Water for the Project will be supplied by GDC. The Project will need approximately 30 m3/day during construction and 10 m3 / day during operations. According to the ESIA, Project construction and operation activities are not expected to strain existing water supplies. GDC is sourcing water from boreholes located in the caldera, in addition to supplying water to the 3 IPPs, GDC will also be using water for its drilling activities and civil works. The PE has developed a Water Resources Management sub-plan for construction and operations which considers among others, options to reduce water demand on site and the prevention of runoff and uncontrolled discharges from site.  

Pollution Prevention 

Air Emissions: During construction, the primary emissions are of dust and particulate matter. These are expected to be addressed through mitigation measures included in the traffic and transport management plan and implemented as part of the EPC’s management plans. The main pollutant of concern during operations is H2S emissions. The Project is located in an area affected by natural sources of atmospheric emissions, including steam, carbon dioxide, and H2S, via natural geothermal features such as vents and fumaroles and in some areas the smell of H2S is noticeable. From the dispersion modelling simulations, (assuming all three power plants are in operation) impacts may be more pronounced to the north (including the villages of Rigogo) and the west (including the villages of Marigo) of the Project. GML intends to use cooling tower fans, which modelling has demonstrated provides good dispersion of pollutants and reduces ground level concentrations. The most conservative modelling scenario shows 2 out of the 12 community sensitive receptors exceeding the H2S concentration considering the Kenyan residential limit guideline of 50 μg/m³. The H2S concentration is however within the WHO daily guideline value of 150 μg/m³.  

GML has developed an Air Quality Management and Monitoring Program (AQMMP) which describes the standards and processes the PE will implement to manage and monitor potential community health and safety impact in relation H2S emissions during operations. Occupational health and safety measures will be defined within GML’s OHS Management Plan as part of the IMS for operations (ESAP #1). The EPRP for construction includes measures related to H2S emergency scenarios (although unlikely during construction, there are natural H2S emissions in the area via natural geothermal features and the adjacent power plant is also now operational) and the EPRP will be updated for operations and will also include measures related to H2S emergency scenarios taking into account community information and drills. 

The AQMMP recommends monitoring of air and odor emissions three months prior to the start and two years of operations of the plant as this will show concentrations from natural sources of H2S as well as venting from the plant. If the concentrations are within the World Health Organization (WHO) guideline and Kenya limit value, monitoring at these locations can be discontinued after the two years into operations. The AQMMP also recommends that as each power station comes online, monitoring should be implemented and continued by each IPP. These results will then demonstrate the incremental as well as cumulative impact from all three power stations. The monitoring data can also be used to verify the dispersion modelling results. In the event that operational monitoring at community sensitive receptors reaches close to or exceeds the national air quality limits community receptors (50 μg/m³), a continuous emissions monitoring campaign will be established (ESAP #2). 

Non-condensable gases (NCGs) constitute on average 3-4% of the geothermal steam from Menengai and are predominantly comprised of carbon dioxide (CO2) about 96%, H2S about 3% and hydrogen, methane and oxygen comprising the remaining 1%. The percentage of NCGs is a key operational parameter of geothermal projects and is continuously monitored as part of operations. 

Odour levels and nuisance are highly subjective, and levels which induce nuisance within communities neighboring the caldera may be higher than average. At most of the monitored wells, the odour threshold is frequently exceeded, however the location directly around the wells and power plants does not include sensitive community receptors. Complaints received around odour will be recorded as part of the GRM and investigated to detect levels and determine whether H2S concentrations exceed target limits. Based on a review of duration and number of incidents recorded in the year, requirements for any further mitigation measures will be investigated. 

Noise and Vibration: The Project ESIA considers noise impacts during both the construction and operations phases of the project supported by a dedicated noise assessment. The noise assessment considered noise emissions as a result of GML’s activities as well as the additional two other plants.  The closest noise sensitive receptors (NSR) are 3.5 km from the plant. The study therefore concluded that NSR will not be affected negatively by noise since: (i) baseline noise levels were already in exceedance of both the Kenyan and WBG EHS guidelines, (ii) GML plant’s design and specifications is planned to contain major noise sources through galvanized steel sheet cladding; and (iii) absence of permanent NSRs within a 2km radius from the plant. A noise management plan as part of the overall occupational health and safety plan for the O&M phase will be developed which will include: pre-employment and routine medical surveillance for all workers, including hearing tests; use of personal protective equipment (PPE) by all workers; controlled vehicular movements; regular and planned maintenance of machinery (ESAP #1). 

Water Quality: The PE commissioned a study to assess thermal contamination of boreholes neighboring the Menengai geothermal field. The study concluded that the elevated water temperature in some boreholes is due to localized and isolated heat sources thought to be buried volcanic centers which are not in close proximity to the Menengai caldera. In addition, as mentioned above GML has developed a Water Resources Management sub-plan which recognizes GDC’s role in the protection of groundwater resources against degradation by steam re-injection activities or brine discharges. GDC has developed and is implementing a water resource management plan and undertakes water quality monitoring throughout the caldera. In the unlikely event that GDC ceases water monitoring activities, GML on (noting its limited leverage) will work with GDC through the Menengai HSE committee to reinstate a water quality monitoring program (ESAP #2).  

Wastewater: The anticipated wastewater streams from the Project include process water effluent from the main and auxiliary cooling water circuit, sanitary wastewater, site surface water drainage. Liquid waste (effluent discharges, surface water run-off, contaminated run-off, foul water discharges, concrete wash out) are covered in the Pollution Prevention and Control Sub-plan. Process water effluent will be disposed of at re-injection wells drilled by GDC. Sewerage waste streams will either be treated on site in a water treatment plant for local discharge subject to meeting general EHS guidelines and others or disposed off site where water treatment plant is not operational through a licensed contractor. All construction related effluent discharges are not allowed on site and all effluent waste is trucked off site. GDC activities resulted in drilling water returns and brine. The drilling water returns were discharged in lined ponds and later reinjected to existing wells to safeguard ground water. GDC has developed and is implementing a groundwater monitoring program. 

Wastes: The Project will generate various types of solid and liquid waste during construction and operations. These include inert construction wastes, hazardous wastes and non-hazardous wastes. The PE has developed a waste management sub-plan for construction and operations and includes provisions for hazardous and non-hazardous waste handling and storage in secure locations, treatment and disposal options and applies the waste hierarchy (prevention, reuse, recycling, recovery, disposal). 

Hazardous Materials Management: Various hazardous and non-hazardous materials will be used for equipment maintenance during construction and operations. For each materials/ chemicals a materials safety data sheet will be available on site and in areas where such materials/ chemicals are used or stored. Personnel working with these materials and chemicals will be instructed and provided with PPE. Hazardous materials management is covered in the Pollution Prevention and Control Sub-plan. The EPC has also included management of hazardous materials in the C-HSSEMP. GML will revise and update the Pollution Prevention and Control Sub-plan to also be applicable to the operations phase (ESAP #1). 

Pesticide Use and Management: The use of pesticides and herbicides is not anticipated for the Project. 

PS4:  Community Health, Safety and Security 

Community Health and Safety: There are no communities within the caldera, communities are located on top, along the rim of the caldera. The closest community is located approximately 3.5 km from the Project.  Access to the caldera is through Mercy Njeri or Wanyororo communities. 

The Project developed and is implementing a Community Health, Safety and Security sub-plan (CHSMP) that considers, among others, issues related influx as a result of potential migration into the area, the Project’s social license to operate due to hazards to community, health, safety and security from project design and infrastructure, emergency events, impact on provisioning or regulating ecosystem services including water supply and others. The CHSMP has adequately included mitigation measures to address the issues identified.  

The PE has also developed and is implementing a Traffic and Transport Management (TPMP) sub-plan that sets out the Project’s requirements to manage impacts resulting from traffic and transportation and outlines standards and controls for the maintenance of equipment and vehicles as well as measures and controls for the safe movement of vehicles for the protection of workers and the general public. The TPMP is completement by the EPC ’s site traffic management plan.  

Infrastructure and Equipment Design and Safety: The design of the plant is based on a single-flash steam cycle with a condensing turbine, a type of technology which is fully developed and well proven in the geothermal power industry.  

Security Personnel:  The Project has developed a security management sub-plan (SMP) in line with PS 4 requirements. The Project is committed to managing the Project’s use of and relationship with third-party security personnel to ensure that security provision is managed properly to safeguard both the security and human rights of communities, workers, and other stakeholders impacted by its operations. The SMP includes a security risk assessment and provisions for security related grievances to be reported via the community grievance mechanism. The EPC contractor has also developed a security risk assessment and security management plan in line with Globeleq’s SMP. Globeleq retains the rights to audit the EPC contractor’s security forces before mobilization or operation using internal staff or using a specialist party. The EPC contractor HSS manager is also responsible to oversee activities of the third-party security and can rely on the support of GML’ Health, Safety and Security manager. 

PS5:  Land Acquisition and Involuntary Resettlement 

The Project will not result in physical or economic displacement as it is entirely within the Menengai Forest Reserve, which is land owned by the Government of Kenya under the custody of Kenya Forest Service (KFS). GDC holds a 30-year Special-Use License for the Land in Menengai Geothermal Project area and has sub-leased a 140×180 meter (m) plot for the development of the Project. 

The 13 km, 132 kV transmission line (TL) and substation constructed and operated by Ketraco in 2016 resulted in economic displacement of 14 project affected persons (PAPs). There was no physical displacement. Farming activities except commercial tall trees such as cypress, eucalyptus and avocado tree can continue taking place in the transmission line wayleave. To address resettlement impacts, Ketraco developed an abbreviated Resettlement Action Plan (RAP) in 2013. As of the time of disclosure, three payments out of the 14 PAPs are pending, one is in stalemate and the other two, landlords cannot be identified. The Ketraco substation and transmission line are considered Associated Facilities to the Project and GML has little to no leverage on the Ketraco operations. 

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources 

The Project occurs within the East African montane forests terrestrial ecoregion. The Project is entirely within the Menengai Forest Reserve (MFR) which contains the Menengai crater. Most areas outside the crater have been converted to human settlements and/or agricultural land uses, except the crater slopes where access is more difficult. Areas within the crater floor have been modified by largely unsanctioned community use (e.g. livestock grazing, wood collection, charcoal production) and permitted development for third party geothermal projects. The Project is entirely within the crater. 

An ESIA, including specialist studies of the project area (e.g. vegetation study) have been completed. Though some gaps exist (e.g. relatively brief baseline surveys for vertebrates), these are considered commensurate to project risks within the area. MIGA conducted additional screening using Integrated Biodiversity Assessment Tool (IBAT), Global Forest Watch (GFW) and associated tools.  

The project area is a mix of degraded Natural and Modified Habitat. The area does not meet thresholds for Critical Habitat but some priority species with potential to occur in the project area were flagged during desktop screening. GML will consult with relevant species experts on likelihood of occurrence of priority species flagged during desktop screening and integrate any recommendations arising into existing biodiversity management plans (ESAP #3). Some nationally protected species (e.g. East African Sandalwood, East African Rock Python) have been confirmed or are suspected and will be managed according to regulatory requirements. No net loss where feasible is required for Natural Habitats. This will be delivered by supporting KFS management efforts including invasive species monitoring and control, management of unsanctioned uses, and restoration using indigenous species. Residual impacts of the Project are not expected to be significant. These actions have been integrated into a Biodiversity Management Sub-Plan (BMSP). Cumulative impacts are expected. The Project will, commensurate with its control and influence, encourage support of MFR objectives by neighboring IPPs (ESAP #4).  

The Project is associated with 13km of 132KV line constructed by Ketraco in 2016. Proximity to Lake Nakuru raises risks of collision by migratory and other bird species associated with the Great Rift Valley migration route and local movements to/from Lake Nakuru. These risks have not been assessed as part of the Project because the line is already constructed and client leverage over this line is limited.. 

Given overlap with MFR, the Project has confirmed legality of overlap with MFR (e.g. KFS sub-lease for the Project), engaged KFS (e.g. establishing Memorandum of Understanding), demonstrated alignment with existing management plans (e.g. integration of MFR management objectives into the BMSP), and has committed to support for additional actions (e.g. proposed reforestation actions within BMSP). 

Invasive alien species (e.g. various plants) are present in the project area. The project BMSP includes actions to monitor and manage alien invasive species within the project area, including commitment to developing an Invasive Species Management Procedure.  

MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities. 

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA. 

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm. 

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below: 

Compliance Advisor/Ombudsman 
International Finance Corporation 
2121 Pennsylvania Avenue NW 
Room F11K-232 
Washington, DC 20433 USA 
Tel: 1 202 458 1973 
Fax: 1 202 522 7400 
E-mail: cao-compliance@ifc.org