[heading subtitle=”KFM Environmental & Social Safeguards“] [/heading]
KOSAP Social Safeguards Standards
KOSAP ensures that through its Result Based Financing (RBF) and Debt Facility, it promotes sustainable business practices among its Solar Service Providers (SSP) and Clean Cook Stoves (CCS) recipients undertaking to improve people’s lives through the provision of clean energy initiatives. KOSAP believes that sound economic growth is grounded in sustainable, productive private investment, is crucial to poverty reduction. Central to KOSAP’s Facility Manager (KFM) development mission are its efforts to carry out its support to Component’s investment activities with the intent to “do no harm” to people and the environment, to enhance the sustainability of private off-grid energy private sector operations and the markets they work in, and to achieve positive development outcomes in their areas of operations. KOSAP is committed to ensuring that the costs of off-grid energy investments do not fall disproportionately on those who are poor or vulnerable and thus its commitment to integrating World Bank OP. 4.10 Indigenous Peoples and also that the environment is not degraded in the process and that renewable natural resources are managed sustainably. KOSAP believes that the recipients’ regular engagement with stakeholders about matters that directly affect them plays an essential role in avoiding or minimizing risks and impacts to people and the environment. KOSAP also recognizes the importance of supporting sector-wide market transformation initiatives that are consistent with sustainable development objectives.
KOSAP is guided by World Bank Environmental and Social Safeguards Operational Policies. Specifically, it is driven by KOSAP Environmental Social Management Framework (ESMF), KOSAP Resettlement Policy Framework (RPF) and KOSAP Vulnerable Marginalized Group Framework (VMGF). The above policies underpin KOSAP’s commitment to mainstream social and environmental sustainability in Component 2 activities to support sustainable off-grid initiatives. The Social Environment Frameworks (ESF) strengthen KOSAP’s efforts to attain socially and environmentally beneficial development outcomes and present an integrated framework for achieving a consistent level of quality in KOSAP’s Component II programming. The frameworks require that all Component II activities enhance positive social and environmental opportunities and benefits as well as ensure that adverse social and environmental risks and impacts are avoided, minimized, mitigated, and managed. Through the ESF application, KFM enhances the consistency, transparency, and accountability of its decision-making and actions, improves performance, and strengthens the achievement of positive development outcomes.
KFM is committed to capacity-building recipients’ staff and implementing partners to manage social and environmental risks and impacts of resulting from SSP and CCS RBF and debt facilities. Key areas of capacity development in ensuring social and environment sustainability include: labor and working conditions; environmental practices; workplace health & safety; community health, safety and security; land acquisition and involuntary resettlement; relations with indigenous communities (vulnerable and marginalized groups), and; preservation of cultural heritage.
KFM develops various safeguards plans Environmental Social Management Plan (ESMP), Vulnerable Marganilized Group Plan (VMGP), Stakeholder Engagement Plan (SEP), Gender Action Plan (GAP) and establishes consultations with recipient stakeholders, describing how risks will be mitigated or avoided. Implementation of these plans typically necessitates their integration into recipient’s corporate policies, practices, and procedures; the development of organizational capacity through training of personnel; and the delegation of persuasive authority throughout the organization to ensure compliance and enforcement.
Community and stakeholder engagement, disclosure, and consultation are informed by KFM safeguards plans and necessitate communication and dialogue between those undertaking the KOSAP SSP and CCS activities and the members of the community affected by it. Engagement efforts are always oriented towards dialogue regarding the risks of the project and the needs and concerns of the local community.
Disclosure regarding project risks and public reporting on the implementation of the Action Plan is always undertaken. Monitoring of the recipients’ activities and ongoing risk assessments is always done throughout the life of the project to ensure compliance with environmental and social framework documents at each phase.
KFM has a robust grievance mechanism on its portal and has established a strong grievance system at the grassroots to assist any concerned party to identify and address concerns of affected stakeholders.
KFM will not support activities that do not comply with KOSAP ESF, national law and obligations under World Bank Operational Policies, whichever is the higher standard. KFM seeks to also support the all recipients to adhere to their safeguard obligations and empower individuals and groups, particularly the most marginalized, to realize their rights and to ensure that they fully participate throughout KOSAP’s activities.
KOSAP Environmental Safeguards Standards
Environmental Safeguards includes broad frameworks and tools for the management and protection of the environment and populations of people and their livelihood activities that could potentially be affected by development activities. The overarching goal of safeguards is “to do no harm” and where not possible to mitigate against known impacts and risks arising from a project.
The Kenya Off-grid Solar Access Project (KOSAP) has been categorized as medium with anticipated impacts range from medium to moderate. KOSAP has 4 components with Component 2 of KOSAP having sub components on Standalone Solar Home Systems and Clean Cooking Solutions respectively to be delivered through RBF and Debt Facilities. The activities expected under component 2 will be minimal and they will be site specific to households that will buy and install the solar devices and clean cooking solutions appliances.
The World Bank Environmental Safeguards Policies that have been triggered under KOSAP component 2 implementation activities are as follows:
- OP 4.01: Environmental Assessment due to the impacts associated with the installation of the standalone solar systems for households. Significant risks include the disposal of batteries, solar PV panels, solar powered devices and clean cooking solutions appliances at their end-of-life phases.
- OP 4.10: Indigenous People due to the known presence of indigenous people/ vulnerable and marginalized groups (IP/VMG) in the 14 KOSAP Service Territories (KST) The first category represented by eight of the project counties- Garissa, Mandera, Isiolo , Marsabit, Wajir, Turkana, Samburu and Narok Counties are overwhelming IP/VMG counties in as far they are inhabited mainly by nomadic pastoralists communities. Tana River, Lamu, Kilifi, Kwale, Taita Taveta and West Pokot counties have minority IP/VMG living among the more dominate communities in each of the counties.
In the Kenya context of Environmental legal framework compliance, the anchor legislation guiding environmental management and monitoring of KOSAP component 2 project activities include the following:
- The Environmental Management and Coordination (amendment) Act (EMCA), 2015
- Environmental Management and Coordination (Impact Assessment and Audit) Regulations, 2003
- Environmental Management and Coordination (Waste Management) Regulations, 2006
- Environmental Management and Coordination (E-Waste Management) Regulations, 2013
- Environmental Management and Co-Ordination (Extended Producer Responsibility) Regulations, 2020 (draft)
- National Sustainable Waste Management Policy 2019
- National E-waste Management Strategy 2019
Mainstreaming of environmental and social safeguards will include due diligence assessment and follow-up on implementation of measures to mitigate against environmental and social risks by the recipients of the SSP and CCS RBF and Debt facilities. Safeguards monitoring will also engage the intended beneficiaries on their perception and awareness of benefits, risks and impacts of the solar products and clean cooking solutions to their environments.