Environmental and Social

1. In terms of promoting shared prosperity, does REA have plans of forming cooperatives in the communities or must a developer create a cooperative in a community?

  • As part of REA’s community engagement activities, communities were encouraged to form themselves into a cooperative known as the Electricity Users Cooperative Society (EUCS). Developers are expected to meet with the members of the cooperative upon arrival to the community.

2. Is the management of lead and lithium batteries in your plan?

  • Yes, it is inbuilt in our plan

3. Who pays for the disposal of the batteries?

  • The issues related to recycling of batteries are built into the extended producer responsibility policy. It is also expected for the developers in their ESMP to provide how they intend to recycle/dispose waste

4. If there is grievance in the community concerning a project, does it mean the developer will have to terminate their project?

  • TA grievance will not necessarily lead to termination of the project if properly resolved. Hence, the need for a robust stakeholder/ community engagement along with a well-publicized grievance Redress Mechanism in order to avoid or mitigate occurrence. Developers should ensure that a grievance does not escalate to the point of affecting the project

5. What role does grievance redress mechanism?

  • The grievance redress mechanism works with the states and NGOs that help the communities understand what these developers do. Stakeholder engagements session in the community with the developer is pertinent for the receipt of a due diligence report. The report of the session must be in a local dialect of the community

6. What role does the National Environmental Standards and Regulations Enforcement Agency (NESREA) play in battery disposal?

  • Once there is a policy direction in place for battery management, NESREA will be responsible for the implementation of the Extended Producers Responsibility (EPR).

7. Can ESMP cost template from the Federal Ministry of Environment be shared with Developers?

  • No, the Federal Ministry of Environment (FMEnv) do not provide a cost template as this is dependent on the consultant hired by the Developer to conduct the Environmental and Social Management Plan (ESMP). The only document the FMEnv can provide is the content of what is required in the ESMP.

8. If there are issues with the ESMP & Environmental and Social Management System (ESMS), can developers reach out to REA when the need arises?

  • Yes, developers can channel all enquiries to the Solar Hybrid Mini Grid team or also schedule a call through the team who will then direct the questions to the NEP Environmental & Social team. The Environmental and Social specialists are always
    available to have a hand holding session or work through with developers as may be required

9. In the E&S, are developers supposed to specify each site by all the itemized requirements in the annexes and are they to approach the State or Federal Ministry of Environment?

  • Yes, developers are supposed to embed all their sites, so long they are in the same state using the same technology, screen their sites using the E&S screening checklist as category 2, which requires the development of ESMP. The ESMP must include the coordinates of all the sites with separate stakeholder/ community engagement.
  • The EIA Act is a Federal Act. Hence Developers are advised to approach the Federal Ministry of Environment who presides over Environmental Impact Assessment (EIA) and not State Ministry of Environment.

10. . If there are some things not captured initially when carrying out the ESMP that later manifest when developing the site, what do developers do and is it possible to replace or take out sites whose agreements have already been signed?

  • The E&S team always stress the importance of using the E&S checklist to categorize sites. It is expected that developers will use experts to conduct all E&S studies, it is expected that possible future issues that might/may arise will/must be flagged from the onset enabling, a proper site categorization to avoid issues that might put the project at risk.