SkyNRG Delfzijl (DSL-01)

International Finance Corporation (IFC) Performance Standards 

Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts; 
Performance Standard 2: Labour and Working Conditions; 
Performance Standard 3: Resource Efficiency and Pollution Prevention; 
Performance Standard 4: Community Health, Safety, and Security; 
Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources;   
Performance Standard 8: Cultural Heritage.  
Equator Principles 4 

EIA and permitting Process According to Dutch regulation, the Project was required to undergo the Environmental Impact Assessment (EIA/MER) process as well as the permitting procedure under the Environment and Planning Decision (Omgevingsbesluit).
The EIA determines and describes how a project may affect humans (including human health), animals, plants, biodiversity, soil, water, air, energy, climate, landscape and cultural heritage. 
The list below describes the steps in the typical EIA process in the Netherlands. 

Environmental baseline assessment 
Current state of noise, air quality, odor, ecology, water, soil 
Protected areas and species (Natura 2000)

Environmental impact assessment based on: 

Climate and energy: CO₂ emissions, energy efficiency, compliance with climate targets
Air quality: Emissions modelling, compliance with quality standards 
Noise: Sound propagation modelling, compliance with noise limits 
Ecology: Nitrogen deposition on Natura 2000, impacts on protected species 
Water: Consumption, wastewater treatment, discharge impacts 
Safety: Quantitative Risk Assessment (QRA), individual and societal risk 
Other: Odor, soil, traffic, landscape impacts 

Best Available Techniques evaluation(BAT) 
Comparison with EU BAT Reference Documents (BREFs) 
Demonstration of BAT implementation 
Justification for any deviations 

Mitigation measures analysis 
Measures to avoid, reduce, or compensate environmental impacts 
Monitoring and management plans 
Emergency response procedures 

A Human Rights Risk Assessment (HRRA) was carried out to identify and evaluate potential human rights risks throughout the project’s lifecycle, focusing on construction and operation phases, business relationships, and supply chain activities. The assessment aims to prevent adverse impacts on rightsholders, including workers, local communities, and supply chain participants. 

Seven salient human rights risks were identified:  

1. Occupational health and safety hazards affecting workers and communities;  

2. Workplace discrimination against women;  

3. Gender-based violence in communities due to worker influx; 

4. Inadequate access to grievance mechanisms;  

5. Forced labor risks;  

6. Land use and contamination affecting communities;  

7. Violations of information and participation rights.

To address these risks, several management measures have been established. These include mandatory health and safety induction training for subcontractors, implementation of SkyNRG’s Ethics & Compliance Policy, Human Rights Policy, HSES Policies, and adherence to Codes of Conduct for both the company and suppliers. Construction workers are protected by collective bargaining agreements. Additionally, induction training covers appropriate behavior and speaking-up protocols, with gender-appropriate facilities provided. The code of conduct guides workforce behavior toward communities, and stakeholder engagement sessions are planned with local communities and NGOs to address concerns and develop mitigation strategies. 

The outcome of the assessment showed that while significant risks exist, clear mitigation strategies are already in place or planned. Overall, the HRRA demonstrated both the scale of risks and the robustness of the management framework to address them. Emphasis is needed on reinforcing grievance channels, promoting gender-sensitive practices, and sustaining inclusive dialogue with communities, so that social risks are effectively managed and long-term project sustainability is secured across all phases. 

Climate change and biodiversity 

A Climate Change Risk Assessment (CCRA) was conducted to identify and evaluate climate-related risks throughout the project’s lifecycle, particularly during construction and operation phases. The assessment aims to develop strategies and mitigation actions to prevent adverse environmental impacts that could affect the environment, workers, and local communities. Impact categories include direct physical damage to structures and equipment, operational disruptions, health and safety risks to personnel, supply chain vulnerabilities, and potential environmental contamination during flood events. 

The most significant climate change risk identified is coastal flooding during both construction and operation phases, which could cause road closures, equipment damage, unsafe working conditions, ground contamination, and potential harm to nearby developments and neighbors. The primary mitigation measure involves maintaining consultation with the local water council to ensure existing flood defense systems are maintained and enhanced according to government guidelines. 

The assessment demonstrates that while the project is broadly aligned with regional and national climate commitments, achieving climate resilience requires proactive implementation of recommended adaptation measures, particularly for water management and flood protection, to ensure operational viability throughout the project lifecycle.  

Regarding biodiversity, a Biodiversity Management Plan (BMP) was developed following international best practices and standards to systematically consolidate mitigation actions identified during the impact assessment. The most salient biodiversity risk is habitat loss and disturbance to special plant and animal species due to work activities during construction and operation. Mitigation measures include periodic spot checks for breeding bird nests before site-disturbing activities, particularly during the March-August breeding season, with exclusion zones established around identified nests. Additionally, quiet pile driving techniques using casing pipes will be employed to reduce peak noise levels to 42-47 dB(A) contours, with exclusion zone distances determined by avifauna specialists.
 
The management plan also outlines clear responsibilities, mitigation actions, and monitoring commitments to ensure biodiversity conservation and the sustainable management of natural resources within the project’s area of influence.