Senegal Banda Gas to Power Guarantee (WB-P145657)

Countries
  • Mali
  • Mauritania
  • Senegal
Geographic location where the impacts of the investment may be experienced.
Specific Location
Kayes, Senegal River, Tasiast, Nouadhibou, Nouakchott
Whenever identified, the area within countries where the impacts of the investment may be experienced. Exact locations of projects may not be identified fully or at all in project documents. Please review updated project documents and community-led assessments.
Financial Institutions
  • World Bank (WB)
International, regional and national development finance institutions. Many of these banks have a public interest mission, such as poverty reduction.
Project Status
Active
Stage of the project cycle. Stages vary by development bank and can include: pending, approval, implementation, and closed or completed.
Bank Risk Rating
A
Environmental and social categorization assessed by the development bank as a measure of the planned project’s environmental and social impacts. A higher risk rating may require more due diligence to limit or avoid harm to people and the environment. For example, "A" or "B" are risk categories where "A" represents the highest amount of risk. Results will include projects that specifically recorded a rating, all other projects are marked ‘U’ for "Undisclosed."
Voting Date
May 29, 2014
Date when project documentation and funding is reviewed by the Board for consideration and approval. Some development banks will state a "board date" or "decision date." When funding approval is obtained, the legal documents are accepted and signed, the implementation phase begins.
Borrower
REPUBLIC OF SENEGAL - MINISTRY OF FINANCE
A public entity (government or state-owned) provided with funds or financial support to manage and/or implement a project.
Sectors
  • Energy
The service or industry focus of the investment. A project can have several sectors.
Potential Rights Impacts
  • Cultural Rights
  • Healthy Environment
  • Housing & Property
  • Labor & Livelihood
  • Right to Food
  • Right to Health
  • Right to Water
Only for projects receiving a detailed analysis, a broad category of human and environmental rights and frequently at-risk populations.
Investment Amount (USD)
$ 99.00 million
Value listed on project documents at time of disclosure. If necessary, this amount is converted to USD ($) on the date of disclosure. Please review updated project documents for more information.
Project Cost (USD)
$ 99.00 million
Value listed on project documents at time of disclosure. If necessary, this amount is converted to USD ($) on the date of disclosure. Please review updated project documents for more information.
Bank Documents
Primary Source

Original disclosure @ WB website

Updated in EWS Feb 26, 2019

Disclosed by Bank May 1, 2013


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Project Description
If provided by the financial institution, the Early Warning System Team writes a short summary describing the purported development objective of the project and project components. Review the complete project documentation for a detailed description.

According to Bank documents, the purpose of this project is "to enable production of natural gas for generation of electricity to reduce the cost and increase the supply for Mauritanian households and industry, and enable regional integration through exports of electric power from Mauritania to Senegal and Mali." The project will:

  • develop pipelines
  • a gas field
  • and the construction of power plants.

According to bank documents, The Banda Gas-to-Power Project involves the development of (a) an upstream offshore gas field (the Banda gas field located55 km off the coast of Mauritania in the North Atlantic Ocean), offshore and on-shore pipelines with a gas processing facility, and (b) the downstream construction of two power plants near Nouakchott in Mauritania and transmission lines to Nouadhibou and Tasiast in the North, all the way down to Senegal to the south. The Banda Gas-to-Power Project aims to develop natural gas resources from the Banda gas field, which will function as the primary fuel source for generated power that will serve Mauritania's domestic, residential, and industrial sectors. The project should also export power to Senegal and Mali. Bank documents further state "Exports to Mali will not require the construction of new transmission infrastructure."
According to Bank documentation, The Mauritanian government "intends that the Banda gas will be used primarily to feed a 300MW power plant in Nouakchott by 2015/16. The project envisions a new transmission line connecting Nouakchott to Nouadhibou and Tasiast (site of the Kinross gold mine). The project could export 80-100 MW to Senegal and Mali through the existing OMVS (The Organisation de Mise en Valeur du fleuve Senegal transmission line links the power networks of Mali, Senegal, and Mauritania to the Manantali hydropower plant in Mali) transmission line. These exports are the object of ongoing discussions between the governments of Mauritania, Senegal and Mali. Power generation may be developed in two phases: a first dual fuel power plant of up to 180 MW that can run on either heavy fuel turbine plant of up to 120 MW. Current estimates indicate that the first phase could start generation by the end of 2014, whereas the second phase would start operating in 2016."

Early Warning System Project Analysis
For a project with severe or irreversible impacts to local community and natural resources, the Early Warning System Team may conduct a thorough analysis regarding its potential impacts to human and environmental rights.

RISK CATEGORIZATION
This project is categorized as a category *A*

With seven triggered environmental and social safeguards, including involuntary resettlement, the World Bank concluded that the project should be categorized as a Category *A* project, the highest possible rating in terms of environmental and social impacts.

The following performance standards were triggered:

PS1: Assessment and Management of Environmental and Social Risks and Impacts
A full environmental impact assessment is under way because of the nature of the risks of the construction of this project. Some of the risks include: vessel collision risk,
economic displacement through loss of access to fishing grounds (in the unlikely event of a spill), water and sediment contamination, discharges of commissioning fluids, noise, habitat loss and impacts to marine and coastal habitats and species, well blowout and pipeline rupture, soil erosion, hazardous materials and waste generation and air emissions (including CO2). According to World Bank documentation *The generation of liquid effluents and the risk of accidental spillage of fuel or chemicals may generate potential impacts on surface and groundwater. All water discharges associated with the project will be treated in an oil/water separator and evaporated (process water and
regeneration of demineralization installations) or treated in a septic tank and left to seep into the ground (domestic effluent). Given the low volume of effluent expected, the lack of surface water in the vicinity of the project sites, and the natural protection of important groundwater aquifers,* the bank maintains, *impacts should be limited.* Noukachott is the most populated city in Mauritania with a population of over 558,000, which makes the 20 kilometer distance between the city and the offshore drilling facility a potential threat to the livelihoods of many.

While the bank does not provide the actual percentage of possibility, World Bank documents state *The risk of a fuel oil (diesel) spill into the marine environment is inherent in all offshore activities. The likelihood (probability) of significant spills, ie those that can reach the coastline or other sensitive areas is very low with most spills being very small and having only limited environmental effects. Considering that the Banda Gas development wells are only targeting gas bearing formations, not oil-bearing formations, the assessment does not consider modeling for spills resulting from accidental well blowouts.*

PS2: Labor and Working Conditions
According to bank documentation *The clients will establish safe and healthy working conditions for their employees, promote fair treatment, non-discrimination and equal opportunity, promote compliance with national employment and labor laws, protect workers, especially vulnerable groups, will not employ children and avoid the use of forced labor. Adequate Environmental, Health and Safety Plans will be prepared and implemented by Tullow, SPEG and their contractors and sub-contractors, as well as SOMELEC, for the Mauritania segment of the South High Voltage Line.*

PS3: Resource Efficiency and Pollution Prevention
According to bank documentation *The clients will avoid or minimize impacts on human health and the environment by reducing pollution from project activities (waste management plans will be prepared as part of the EMPs in the case of the upstream component). The clients will promote more sustainable use of natural resources, such as water and energy, and reduce project-related greenhouse gas (GHG) emissions.* World Bank documents further state *Best practice and good operation management will be applied to enhance efficiency and where possible minimize CO2 emissions.* World bank documents also identify *Greenhouse gas reduction strategy with focus on optimisation of overall energy efficiency and reduction in flaring and venting: as a mitigation and management measure for greenhouse gas emissions. It is unclear of as to whether these are the best technologies available as the document does not specify.

According to World Bank documents *Mauritania currently does not have any specific national standards and procedures for the regulation of air quality. The Environmental Code states the requirement to avoid or minimise gaseous pollutant
emissions, if susceptible of harming persons or goods.* World Bank documents also state that the Independent Finance Company will adhere to *World Health Organization (WHO) Air Quality Guidelines* and the World Bank documents further claim *According to the impact significance levels described above, impacts on local air quality due to NO2, CO and PM10 ground level concentrations induced by the combustion of purge gas at the High Pressure and Low Pressure flares have been assessed as Negligible.*

There are no alternatives to using gas mentioned in the documents. World Bank documents claim *In Mauritanian law* no national guidelines exist for wastewater and liquid effluents quality. Therefore the International Finance Corporation (IFC) criteria have to be considered for this Project.*

In order to extract the gas, *Drilling for oil and gas uses a rotating drill bit attached to the end of a drill pipe (the' drill string') to bore into the subsurface to reach trapped oil and/ or gas. The first stage of drilling is to drill the well top hole, following which a conductor casing is lowered into the hole and cemented into place. The second well section, known as the surface section, is then drilled using a smaller drill bit and the surface casing lowered and cemented into place. At this stage a Blow-Out Preventer (BOP) and marine riser are installed onto the well. The marine riser connects the well to the Mobile Offshore Drilling Unit forming a closed loop system. Once in place, drilling continues using a series of progressively smaller diameter drill bits and casings as the well is drilled deeper. The casings are lowered down the hole through the previous larger diameter casing section and cemented into place. The rotating drill bit breaks off small pieces of rock (called drilling cuttings) as it penetrates rock strata. The cuttings typically range in size from clay to coarse gravel, and their composition will vary depending on the types of sedimentary rock penetrated by the drill bit. Drilling fluid, also known as drilling mud, is pumped down inside the drill string to lift the cuttings from the bottom of the well to the surface. Additionally, the purpose of the drilling fluid is to maintain positive pressure in the well, to cool and lubricate the drill bit and to protect and support the exposed formations in the well.

PS4: Community Health, Safety & Security
World Bank documents state *The clients will anticipate and avoid impacts on human health and safety of nearby communities, personnel and property. Workers will be housed in Nouakchott, so that no separate worker camps will be needed. Tullow, SPEG and their contractors and sub-contractors will carry out HIV/AIDS prevention activities. The Environmental Social Impact Assessments/Resettlement Policy Frameworks prepared for the three components have consulted upon with institutional stakeholders as well as with the potentially affected population.*

World Bank documents further state *Power plants typically pose a potential risk to the safety of the workforce and communities due to the use and storage of flammable / explosive gas (natural gas/oil products) and the operation of equipment under high pressure." Fire and explosion hazards have been assessed in the EIA in Chapter 7. It appears from this study that all hazards related to Lethal Effect Threshold and Significant Lethal Effects Threshold remain contained within the site boundaries. Only one scenario, the Boil-Over of a heavy fuel oil tank (dual power plant) models the radius of influence i.e. the Threshold of Irreversible Effects (SEI) to human health, exceed the site boundaries by a few meters. Apart from this scenario, no irreversible consequence (serious effects to humans) is likely to occur outside the site boundaries. In case of accident, serious damage to people outside the site is not expected.*

In order to ensure the safety of the power plants, World Bank documents also claim *For the SPEG Power Project, downstream power generation and transmission infrastructure, SPEG has developed a full ESIA and a Resettlement Policy Framework (Resettlement Policy Framework) for the SPEG project, including the
North High Voltage line and the OMVS High Voltage line extension. The SPEG and SOMELEC environmental and social management systems are weak so it will be required that they will outsource monitoring of the environmental and social aspects of their operation in relation to this project in order to ensure an acceptable level of environmental and social management integrity.* Bank documents do not mention whether there exists potential violent conflict between groups in the region.

PS5: Land Acquisition and Involuntary Resettlement
According to bank documentation *The Resettlement Policy Framework (RPF) for the SPEG Power Project covers the land acquisition necessary for the construction and operation of the gas pipeline from its point of landing to the gas processing and power plant site. An RPF has been prepared because final sitings and alignments are yet to be determined for the onshore civil works in Mauritania (gas processing and power plant sites, transmission lines); resettlement impacts are expected to be moderate. Tullow and the Government of Mauritania are discussing which of them will pay the compensation; both sides have agreed that such compensation will be undertaken in accordance with PS 5. For the downstream portion, SPEG will handle any compensation related to the power plants and SOMELEC will handle any compensation related to the transmission lines. The RPFs for the South HV Line for the Mauritania and Senegal segments prescribe that, when the final corridor for the transmission lines (both for the North and South High Voltage Lines) have been selected and it has been identified that people will be affected, Resettlement Action Plans will be prepared, consulted upon, and disclosed before any construction activity starts.*

PS6: Biodiversity Conservation & Sustainable Management of Living Natural Resources
According to bank documentation *The Banda Gas-to-Power upstream and downstream project components may encounter sensitive marine and terrestrial ecosystems, including natural habitats. These potential impacts have been identified by the three Environmental and Social Impact Assessment (ESIAs). Adequate safeguard management plans have been developed as part of the Environmental Impact Assessment (EIA). This World Bank Performance Standard has been triggered even though the impacts on marine and terrestrial biodiversity have been evaluated as manageable.* World Bank documents further state **The ESIA assessed several possible corridors and on the Mauritania side concluded that the best compromise between economic, social and environmental imperatives would to
recommend a corridor that would avoid passing through the Diawling National Park, an important migratory bird nesting place that made the park a recognized Ramsar site in 1994. However on the Senegal side it would be very difficult to avoid the Senegal River delta and avoid passing near sensitive ecological areas such as the Djoudj national Park. An alternative route is proposed in the ESIA in order to minimize the impact, particularly on birds, on the sensitive ecological zones mentioned as the line crosses the Senegal River. The extra length of line would be 11km.**

PS8: Cultural Heritage
According to bank documentation *The Banda Gas Project Environmental and Social Impact Assessment (ESIA) has identified 13 cultural heritage Late Stone Age sites on the project footprint of the gas treatment plant. An adequate cultural heritage management plan has been developed as part of the Environmental Management Plan. The SPEG Environmental and Social Impact Assessment (ESIA) did not identify any cultural heritage sites in the project area. The South High Voltage line Environmental and Social Impact Assessment (ESIA) has not reported significant potential cultural heritage sites in relation to that infrastructure* According to World Bank documentation *An independent Mauritanian archaeologist was then contracted to undertake a site reconnaissance study in order to confirm the cultural heritage value of the site and suggest recommendations on measures to be implemented in order to be compliant with Mauritanian regulations in terms of cultural heritage.

The bank claims that there are no indigenous populations living in the area of construction, so PS7 is not triggered.

People Affected By This Project
People Affected By This Project refers to the communities of people likely to be affected positively or negatively by a project.

ENVIRONMENTAL AND HUMAN RIGHTS ASSESSMENT

Right to a Healthy Environment

The first principle of the 1972 Stockholm declaration states *Man has the fundamental right to freedom, equality and adequate conditions of life, in an environment of a quality that permits a life of dignity and well-being, and he bears a solemn responsibility to protect and improve the environment for present and future generations.*
This project requires the construction of power plants and a line that will run from Mauritania to Senegal and Mali. The drilling alone has the potential of having detrimental impacts on the environment]. World Bank documents, however, state *The majority of these impacts from the drilling, completion, installation, and commissioning activities were assessed as being Negligible or Minor*. Still, **the potential impacts resulting from an unlikely spill or hydrocarbons at sea were assessed as moderate. These would be assessed with an accidental loss of fuel from mobile offshore drilling unit of the supply vessels used in the drilling subsea, subsea installation, or pipelay phases.*

While the possibility of an oil spill exists, World Bank documents claim *Tullow's proposed emergency response procedure would likely prevent the majority of diesel reaching the shoreline.* It is also believed that that drilling should not affect sea users and sea life because all drilling will occur *at a distance of 55km away from the coast.* It is noted, however, that drill cuttings discharge offshore could cause elevated levels of total suspended solids concentration and depositional thickness. The environmental impact assessment claims that it should be *short term and dissipate rapidly as a result of the dispersion capacity of the local marine environment.*

World Bank documentation further states that in order to prevent and train for fire outbreaks *Emergency response plans and teams have been established to address reagent and fuel spills, fires, and accidents requiring medical attention.* Mitigation and management measures in Bank documents include: *Active fire protection; Gas leak detection devices; Development of a fire and life safety plan for workforce; Coordination with local authorities for external emergency response; 300m exclusion zone without permanent infrastructure (except Project infrastructures) around the gas treatment plant; Markers will be provided to prevent accidental excavation damage to the pipeline, and umbilical 60 m exclusion zone with no permanent infrastructure on both sides of the pipeline; Periodic monitoring of the onshore part of the pipeline to reduce the likelihood of any intentional damage to it.*

There will also be the prevalence of hazardous materials that will impact the environment due to the construction of the project. The hazardous materials include: batteries, chemical residues, clinical and medical waste, oil filters, oil rags and absorbents, and used oil. Likewise, the development of this project will generate varying amounts of air pollutants and greenhouse gas emissions from combustion sources such as generators and thrusters on the Mobile Offshore Drilling Unit, diesel engines on the support and installation vessels and flare emissions from the gas plant will thus increase yields of greenhouse gas emissions within the communities which overlaps with the right to a healthy environment.

The following questions should be raised to determine whether or not these communities have had violations of human rights due to the construction of this project:

  • Has the government provided information on an environmental action plan in place for reducing the ecological effects on local communities after the construction of this project?
  • What options do you have (legal or otherwise) if the environmental impacts of the proposed operations become a problem for local communities?
  • Do you feel that your natural environment (air, water, land, animals, and plants) has changed since the start of the investment project?
  • Where will solid waste, hazardous waste, and other waste products be disposed of and what impact is this likely to have on the local environment?
    Do those implementing the project have an adequate plan in place for preventing increases in disease or for providing health care should diseases become a problem?

Right to Water

Fresh water sources are particularly difficult to find in this part of the world. The proposed product has the possibility of depleting potential fresh water sources and causing harm to the communities that rely on nearby water sources. According to the Environmental and Social Review Summary, *The generation of liquid effluents and the risk of accidental spillage of fuel or chemicals may generate potential impacts on surface and groundwater.* The potential risk of providing an avenue of chemicals to enter water sources could result in the right to water being infringed upon. The Environmental Impact Assessment makes clear that oily water slops and contaminated water are an expected outcome from the construction of this project.

The following questions should be raised to determine whether or not these communities have had violations of human rights due to the construction of this project:

  • Do you have reason to believe that your access to safe, affordable and sufficient water could change as a result of the planned investment project?
  • What means of redress (legal or other) are available if you feel that your right to water has been affected?
  • Have you been informed of any potential changes that could affect your access to water?
  • Are there laws, policies or programs protecting the right to water in these countries?
  • Does the government have proper mechanisms in place to enforce its laws to protect water sources and the right to water of its population?
  • Does the company have adequate safeguards in place to prevent waste products from being carried into and contaminating nearby rivers or other water sources?

Right to Labor
Labor rights are implicated by this project because there are claims that it will temporarily create jobs for nearly 800 workers. The employees will be 250 to each power plant, and 110 jobs will be created specifically for the construction of the transmission lines. Bank documents also state that *The south High Voltage line will employ up to 600 workers during the construction stage.* Additionally, 150 permanent jobs should be available during the operational stage. It is imperative that these guarantees are fulfilled. It is also very possible that fishermen near the construction sites would be encroached upon by the construction of this project.

According to World Bank documents *The project is located in the vicinity of Noukachott which is the largest urban centre in Mauritania, and speculative job seekers are likely to live in Noukachott already*. There are no guarantees that jobs will go to locals. However, World Bank documents claim that all openings will *Publicly advertise Tullow' s in-country recruitment procedure.*

The following questions should be raised to determine whether or not these communities have had violations of human rights due to the construction of this project:

  • Are working conditions in the community, and/or in this industry, safe and healthy?
  • What opportunities for recourse (legal or otherwise) are available if you consider that your working conditions are unjust?
  • Can the workers in your community and/or in this industry bargain for better working conditions?
  • Are women and men in your community and/or in this industry equally free to form unions, join a union of their choice, bargain for better working conditions and/or go on strike?
  • Does the company have a policy to ensure respect for the right of its workers to freedom of association and collective bargaining?

Right to Food

There is a population of 1500 traditional village fisherman known as the Imraguen peoples who fish along the shallow coastline approximately 15km east of the construction site. There is a possibility that pollution could deplete the marine life in that region and as a result they would not have access to food.

World Bank documents state *Discharges from project vessel contaminated with traces of hydrocarbons can affect water quality with secondary impacts on marine fauna*. World Bank documents further claim *Discharges of ballast waters (from Mobile offshore Drilling Unit and other vessels) can impact on water quality and marine fauna. Risk of introduction of invasive species.* It is worth noting that the World Bank still claims that *There are no indigenous populations living in the area of construction site.* [It is worth noting that the possible affected traditional village fishermen known as the Imraguen peoples are not considered indigenous people by World Bank standards and they may be impacted by the creation of this project.]

The following questions should be raised to determine whether or not these communities have had violations of human rights due to the construction of this project:

  • Is there reason to believe that this investment project could result in a loss of food?
  • Is there a policy or program that will ensure that this investment project will not interfere with the right to food?
  • Have project officials included community members in assessments and plans addressing threats to food security?
  • Do you and your community have access to food in sufficient quantity?
  • Do you have reason to believe that the planned expansion of the project will affect your community's access to food? If so, how?


Right to Housing & Property

The resettlement action plan states that there are approximately 10 families who will be relocated from Mauritania around Nouakchott. There will be others who will be temporarily relocated. The total amount of compensation for resettlement has not been fully determined. A report from Amnesty International published in 2013 has documented instances in Senegal in which individuals have been resettled to make way for international companies to profit.
In all likelihood, within the scope of the study of this project, the construction and operation of certain infrastructure risk potentially reaches a number of actors, which was estimated. The assessment of the number of third parties that may be caused to undergo partial restriction of use of land occupied, mainly because of the servitude associated with power lines (home or business commercial or farming, particularly in peri-urban areas) is 46 families. 36 families will need to temporarily relocate, but only 10 families will be permanently relocated.

The following questions should be raised to determine whether or not these communities have had violations of human rights due to the construction of this project:

  • Have people in your community ever been forcibly evicted from their homes?
  • Has the housing provided following relocation been adequate and of equal or better quality than the housing previously occupied?
  • Do you feel as though you have been justly compensated for resettlement?
  • Have you and your community had an opportunity to provide meaningful input at each stage of the project design and planning, including on economic resettlement plans, and provide suggestions about alternatives to relocation?
  • Was there evidence that the company had adequately considered and responded to your input?
  • Do you have reasons to believe that your access to adequate housing could change once the investment project begins?
  • Are there human settlements (shelters, homes, villages and/or communities) adversely affected by the presence of this project?
  • Have there been any complaints of forced evictions in the context of this investment project?
  • Will households resettled for this project actually be compensated properly?
  • Will communities resettled for this project move voluntarily?
  • Will the resettlement area provide access to similar sources of livelihood as previous locations?
  • How will appropriate compensation for lost trees, facilities and other assets be determined?

Right to Culture

The Banda Gas Project Environmental and Social Impact Assessment (ESIA) identified 13 cultural heritage Late Stone Age sites in the vicinity of the project footprint of the gas treatment plant. An adequate cultural heritage management plan has been developed as part of the Environmental Management Plan. Moreover, there is a risk that underground ancient burials may be encountered during disturbing activities. World Bank documents claim that *There are no indigenous populations living in the area of construction site.* It is once again noted that the possible affected traditional village fishermen (The Imraguen peoples) are not considered indigenous people by the standards of the World Bank, and that they may be impacted by the creation of this project.

The following questions should be raised to determine whether or not these communities have had violations of human rights due to the construction of this project:

  • Has the local community been properly notified of interruption?
  • What steps are being taken to prevent disturbance of these sites?
  • Will the construction damage culturally important sites?
  • Has the project interfered with the right to engage in cultural activities?
  • Has your community has been discriminated against because of its culture as a result of this proposed project?
  • What opportunities (legal or other) are available if you feel that your right to take part in cultural life has been restricted or denied?

Right to Health

According to the World Health Organization, *The right to health means that governments must generate conditions in which everyone can be as healthy as possible. Such conditions range from ensuring availability of health services, healthy and safe working conditions, adequate housing and nutritious food.* With the construction of two power plants and a High Voltage power line, pollution will surface in the area. With an increase in greenhouse gas emissions and affected soil, there is a high risk that individuals will find themselves subject to debilitating health effects.

The following questions should be raised to determine whether or not these communities have had violations of human rights due to the construction of this project:

  • Have you been informed of any potential public health problems that may occur as a result of this investment project?
  • Are there means of redress available if you feel that your right to health has been affected?
  • Has the government considered the possibility that this investment project could affect people's fundamental right to health?
  • Has the company inquired about possible problems related to the right to health in the planned investment project area?
  • Have the companies involved inquired about the possible involvement of its joint venture partners, subsidiaries or sub-contractors in violations of the right to health?
  • Has the company (or any joint venture partners, subsidiaries or sub-contractors) been accused of causing public health problems or affecting people's right to health in other regions or countries?
  • Does the company involved in the construction of this project have policies or procedures to ensure that its activities do not cause public health problems or affect people's right to health?
Investment Description
Here you can find a list of individual development financial institutions that finance the project.

The borrowers are the Republic of Senegal, The Islamic Republic of Mauritania, and the Republic of Mali. The Guarantor is the International Development Association and the Multilateral Investment Guarantee Agency of the World Bank. Gas Joint Venture Partners, Society de Production de Electricita  partir du Gaz (SPEG) and Society Mauritanienne de Electricita (SOMELEC) are sponsors and beneficiaries of the investment. To date, there have been no complaints filed against the World Bank for the construction of this project.

There have not been any complaints filed to the World Bank Inspection Panel regarding Bank-supported projects in Senegal, Mauritania, and Mali to date ( have not, (but there are previous human rights abuses in these countries that have been documented by various organizations, some of which are summarized below).

Tullow Oil is considered an Independent Finance Corporation involved with the design, development, and the operation of all constructed facilities. Tullow Oil has its own environmental standards that are applicable to all of its operations. Tullow Oil has four key areas with a set of its own project tools to support the delivery of the finished product. The four areas are: Biodiversity, Greenhouse Gases, Resource Management, and Social-economic aspects. With the issue of biodiversity in mind, Tullow Oil seeks to avoid negative impacts to biodiversity. With greenhouse gases, Tullow Oil aims to promote efficient use of energy and responsibility. With Resource management, Tullow Oil promotes the sustainable use of natural resources. Finally, Tullow Oil wants to avoid any potentially negative impacts on the socio-economic welfare of the local communities involved with the construction of various projects. According to bank documents, "Tullow always ensures compliance with national labor laws and Independent Finance Corporations (IFC) Performance Standard 2." Standards and policies are claimed to be reviewed on an on-going basis during projects to ensure that they are constantly updated and remain compliant with any defined standards. According to bank documents "Tullow's safety rules are designed to manage high risk activities that have the potential to have a negative impact on their staff, the environment, and the surrounding communities." Likewise, bank documents state "Tullow will prevent community disturbance through eliminating or reducing disruption at an acceptable level." It is worth noting that Mauritania "currently does not have any specific national standards and procedures for the regulation of noise." In fact, according to bank documents "no legal thresholds exist at this time during the drafting of the EIA" which refers to the Environmental Impact Assessment.

PAST BANK FUNDING

World Bank documentation states "The World Bank has approved 122 projects for Senegal totaling about US$3.0 billion. The commitment value of 20 ongoing International Development Association (IDA)-financed operations is about US$700 million equivalent, with an undisbursed balance of about US$460 million. The 20 operations are in agriculture, rural development, infrastructure, environment, transportation, population/health/nutrition, social protection, energy/water, public and private sector development, and natural disaster management. Portfolio performance is discussed quarterly with the government."

Regarding Mauritania, World Bank documentation states "At present, the Bank's portfolio in Mauritania includes six International Development Association (IDA) funded operations, including two regional projects, representing a total commitment of $165 million. The IDA portfolio is complemented by a number of trust funds, for a current total committed amount of $25.5 million."

In regards to Mali, World Bank documentation states "The IDA portfolio in Mali amounted to US$892.25 million composed of 21 operations, including seven regional operations. A breakdown of the portfolio by sector is as follows: Energy 25%; Transport 18%; Rural Development 25%; Public Sector Development 17%; Human Development 4%; Environment 7%, and Private Sector Development 4%."

PAST HUMAN RIGHTS ABUSES

According to Amnesty International, "Rights to land are being sold from beneath the feet of rural communities in mining areas as the government of Senegal grants concessions to mining companies without safeguarding human rights in a flagrant breach of their duty under international law". Amnesty International elaborates by stating "communities are being relocated without due regard for the impact on their livelihoods and access to food and water to make way for international mining companies, eager to exploit the country's rich reserves of gold and other minerals."

As for Mauritania, according to a report from Amnesty International in 2013 "The authorities severely restricted freedom of expression, assembly and association. Protesters marched throughout the year, demanding the departure of President Mohamed Ould Abdel Aziz. The authorities continued to threaten anti-slavery activists. Former Libyan intelligence chief Abdullah al-Senussi was arrested and extradited to Libya, where he could face the death penalty. At least six people were sentenced to death."

As for Mali, a report from Amnesty International published in 2013 claims that there are still child soldiers being reared by the government and an armed militia, the right to education has been undermined by AQIM (Al-Qaeda in the Islamic Maghreb) who forbade teaching French in public schools, the right to culture was undermined as Islamic groups destroyed mausoleums, at the end of last year, 14 hostages were held by AQIM in the north. Some of the hostages were nationals from different countries.

In terms of rights abuses by Tullow Oil, Ugandan newspaper The Daily Monitor asserts "Women, accordingly, have become vulnerable to prostitution, domestic violence due to property and sexual exploitation in oil camps; but Oil companies Tullow and Total' representatives repulsed the claims."


Contact Information
This section aims to support the local communities and local CSO to get to know which stakeholders are involved in a project with their roles and responsibilities. If available, there may be a complaint office for the respective bank which operates independently to receive and determine violations in policy and practice. Independent Accountability Mechanisms receive and respond to complaints. Most Independent Accountability Mechanisms offer two functions for addressing complaints: dispute resolution and compliance review.

Borrower
Contact: Mamadou Amadou Kane
Title: SPEG General Manager
Email: pakpus@hotmail.com

CONSULTATION PROCESS

According to the Environmental Impact Assessment, "Stakeholder engagement activities started during the scoping stage of the project and ran throughout the Environmental Impact Assessment. The objective was to ensure that sources of existing info and expertise are identified, legislative requirements are met and that stakeholder concerns and expectations are addressed. 26 consultation meetings were held with stakeholder groups or organizations from Nouakchott and coastal communities in July 2012 and between November 2012 and February 2013. A public consultation meeting attended by nearly 60 representatives of ministries, local governments, fishermen unions, and non-governmental organizations was held on 20th March 2013 in Nouakchott."

ACCOUNTABILITY MECHANISM OF WORLD BANK

The World Bank Inspection Panel is the independent complaint mechanism and fact-finding body for people who believe they are likely to be, or have been, adversely affected by a World Bank-financed project. If you submit a complaint to the Inspection Panel, they may investigate to assess whether the World Bank is following its own policies and procedures for preventing harm to people or the environment. You can contact the Inspection Panel or submit a complaint by emailing ipanel@worldbank.org. You can learn more about the Inspection Panel and how to file a complaint at: http://ewebapps.worldbank.org/apps/ip/Pages/Home.aspx.

How it works

How it works