Additional key environmental, health, safety and social (EHSS) issues associated with this project include:
- environmental assessment and management;
- labor policy and contractor management;
- management of construction activities and wastes;
- temporary traffic disruption and community safety during construction;
- cultural property; and
- worker health and safety during construction and operations phases.
The project is otherwise of obvious positive benefit as it will generate electricity from a renewable resource. The impacts associated with these additional issues can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. AGE has completed an independent EIA, independent Supplementary EA, public consultation and will conduct additional consultation as defined below, developed a detailed EMMP and has committed to conduct its activities in accordance with measures contained within the EA documentation, including the original EIA, the EMMP, and will, upon implementation of the EMMP and specific additional measures described below, comply with the IFC Performance Standards on Social and Environmental Sustainability.
- PS1: Social and Environmental Assessment and Management Systems:
As required under The Bulgarian Environmental Protection Act (1991) and EU EIA Directives an independent EIA was commissioned and completed during the period 2006-2007. This EIA process included public consultation and disclosure with local stakeholders and affected communities. Based on anticipated impacts on an important area of steppe habitat and visual density impacts, the project scope, as a result of the 2006 EIA, was reduced from 62 to 52 turbines. On completion of this study and consultation the EIA was approved by the relevant Bulgarian authorities in 2007. In order to meet the specific requirements of the IFC Performance Standards and the requirements of other lenders, independent supplementary environmental assessment, comprising of the Supplementary Information Report (SIR), Environmental Management and Monitoring Plan (EMMP), Public Consultation and Disclosure Plan (PCDP) and Non Technical Summary (NTS) as listed above, were completed as part of the EA process in June 2008. This set of documentation clearly defines the comprehensive mitigation measures, procedures, plans and systems AGE will establish and implement to ensure the project is managed in accordance with the applicable requirements. The documents include a discussion of site selection, detailed collision risk assessment and cumulative impacts (in terms of avian and visual/landscape impacts). Furthermore the EA includes assessment of the incremental and cumulative impacts of bird collision risk associated with the project’s Transmission Line (T-Line).
With respect to alternatives and site selection, AGE followed a process involving a first stage of selecting a wind farm site using an Area of Search primarily based on an EBRD analysis of the Bulgarian wind resource (see the SIR Appendix 1) and internationally and nationally important environmental designations including Natura 2000 zones and known sensitive bird areas (see SIR Appendix 2). From this analysis, an Area of Search was then defined based upon three areas of interest within Bulgaria. To select among the three areas the following factors were reviewed for all three areas of interest within the Area of Search during 2002:
- potential wind resource;
- centres of population, and proposed future development where known;
- engineering considerations (such as major roads, overhead cables, possible grid connections);
- landscape and topography;
- nature conservation; and
- cultural heritage.
Based on a comparison of the cost benefit for each factor, a preferred area for wind farm development was selected. The Kavarna region was chosen as the preferred area due to a combination of:
- the availability of a good wind resource - the mountainous area to the south of Sofia and the Stara Planina mountain range are subject to turbulent wind conditions and icing during winter;
- good general grid access and capacity;
- good general access for construction in the area; and
- environmental considerations.
In regard to the specific environmental considerations inland from the coast, land within the Kavarna region has been highly modified by intensive agricultural activity; most of it is no longer native steppe habitat. The area was therefore considered to be less sensitive than the mountainous area to the south of Sofia and the Stara Planina mountain range which are dominated by large tracts of nationally important wild forests. It was concluded that these areas would suffer greater environmental and social impacts as a result of wind farm development compared to the Kavarna region as they are relatively untouched.
The key tool for achieving the requirements and mitigation measures identified in the EA process is the Social and Environmental Management System (SEMS) that AGE will develop to manage all impacts through design, construction and decommissioning. The SEMS will set out the policies and procedures required to manage environmental and social impacts of the project to comply with applicable Bulgarian and EU legislation as well as the requirements of the IFC Performance Standards and the specific requirements contained within the project’s EMMP. This EMMP addresses all phases and components of the project.
The EMMP describes and prioritizes the actions needed to implement mitigation measures, corrective actions and monitoring measures necessary to manage the impacts identified within the EA. Key elements of the EMMP include:
- Establishment of an ongoing 3 year independent avian monitoring plan;
- Installation of a radar system, which together with visual observation, will determine annual and shifting turbine shutdown needs based on approaching migrant flocks over the site; and
- Marking overhead power lines with bird deflectors to increase visibility and painting of turbine blased in appropriate colors to increase visibility.
The EMMP will be a dynamic working document, which will continuously evolve over the course of the project design, construction, operation and decommissioning. The EMMP also includes detailed requirements with respect to: Emergency preparedness and response; Waste Management (including materials storage and handling arrangements); Water Management; Traffic Management; Land Reclamation (from road and foundation construction); and Wind Farm Decommissioning.
Furthermore AGE has committed that periodic yearly reports on the implementation of the EMMP will be produced and disclosed locally. These plans will be developed and agreed in consultation with the relevant Bulgarian authorities.
- PS2: Labor and Working Conditions:
Erection of the turbines will be undertaken by Vestas. All other structures and facilities, comprising turbine foundations, the substation, T-Line, and all related civil and electrical works, will be subcontracted by AGE to third parties whom AGE will manage. Vestas will operate and maintain the turbines for a period of 5 years. AGE will be responsible for the Operation and Maintenance (O&M) of all other structures and facilities during this period; after the expiry of Vestas’s turbine maintenance contract, all O&M for the Project will revert to AGE. To address the construction and operating regime as designed above, AGE will establish a written HR Policy consistent with this PS and will provide access of this to all staff, both employee and non-employee workers. All contracts with contractors and subcontractors will include a clause requiring compliance with PS2. AGE and Vestas permit collective bargaining, and subcontractors will be similarly required to allow collective bargaining. Vestas operates to international best practice standards in it’s wind farm construction and operations and maintains a corporate SEMS. Best practice international, and indeed EU safety standards, will apply to occupational safety with regard to use of personal protective equipment, work procedures (for tower erection and maintenance) and equipment movement. All employees will be provided with the necessary training and safety equipment as required for their respective responsibilities and duties.
- PS3: Pollution Prevention and Abatement:
The project is implicitly a net benefit from a pollution perspective as it will generate electricity from a renewable resource and carbon/emission credits. The wind farm is located in a moderate wind regime. The capacity factor of the wind farm has been independently assessed by engineers to be approximately 25% at p50 and 20% at p90. The project is expected to lead to emissions reductions of approximately 0.9 tCO2e / MWh according to AGE.
Construction and maintenance will nevertheless generate a limited amount of general waste (packaging, metals, plastics, filters, oils etc.) which will be disposed of in designated places by licensed contractors. Closed systems will be used to prevent operational spillages of fluids, fuels, oils and toilet waste.
It is proposed that 42km of existing municipality-owned dirt roads will be repaired and/or expanded to facilitate construction of the turbines and their foundations and sub-station. Once construction is completed, it is intended to maintain the roads to enable maintenance activities. Existing roads will also be used for underground cabling purposes (between turbines and the substation) and reclaimed to their original state after cable installation. Road expansion during construction will require proper drainage and erosion management, for this specific contractor actions and responsibilities have been defined in the EMMP.
Dust emissions from excavation and vehicle movement will include the use of road watering and revegetation, with indigenous plants/species, of any disturbed areas. Water sources for this watering will be sourced from approved sites and are not anticipated to cause impacts on other users or local resources.
Contractors will be required to implement specific waste oil and fluid storage, recycling and disposal procedures. Once the project is operational, there will be very limited pollution risk from the Project due to the closed systems used within the turbines and limited site activities; periodic oil and fluid changes of geared equipment will be conducted and waste oils/fluids will be recycled or disposed of at designated sites.
In terms of mitigation measures it is proposed that there will be no groundwater or surface water abstraction and that chemical toilets will be provided on site. All grey water from sinks will be disposed of to ground. Measures will be put in place to ensure that no chemicals will be spilled thus minimising the risk of ground and surface water pollution. Following the implementation of these measures, it is considered that the will be no significant impacts associated with waste. These measures are addressed in detail in the EMMP.
- PS4: Community Health, Safety and Security:
The main risk to communities relates to the construction rather than operational phase of the project. Key risks posed to the community relate to traffic movement, noise, visual impact, and shadow flicker.
During construction oversized vehicles will transport heavy equipment and parts (e.g., rotor blades) on local roads. The need for a formal Traffic Management Plan has been established and the specifics of this is detailed in the EMMP. The plan will define optimal traffic movement times, notices that need to be given to communities and training and information that needs to be provided to contractors. In addition the plan must ensure that traffic speeds, signs and controls are put in place and that employees and local people are made aware of these. This plan will be disclosed to the public closer to the time of construction in coordination with local authorities.
With regard to noise impacts, the closest receptors are located approximately 1.2km from the nearest turbine and predicted noise levels will not exceed the 45dB and will thus comply with IFC PS requirements. Further noise testing will be conducted based on mircositing and noise monitoring will be undertaken on a regular basis during the course of operations in order to ensure that levels remain within acceptable limits.
In terms of visual impacts, the landscape in the area is composed of flat terrain significantly altered by many centuries of human habitation and cultivation. The area is dominated by agricultural cultivation bordered by thin bands of forest shelter belts. Several small existing wind farms and turbines currently form a core part of the landscape character. A site farm within 2 km of the project site is to include 35 turbines. In this context, whilst the Project adds a significant structures into the landscape, it’s scale and layout is considered unlikely to significantly alter the existing character of the landscape. It is evident from the Zones of Theoretical Visibility (ZTV) assessed in the EA that the extent of the visual envelope which results in combination with the other developments in the region remains largely the same. Viewpoint photographs and wirelines serve to reinforce these findings, showing that the Project would be highly visible from a number of viewpoints but appear congruous with the existing turbines within the views. Overall it is considered that the introduction of an additional 52 turbines associated with the Project will not result in a significant adverse effect on the prevailing landscape character or on the visual amenity of the local and wider landscapes. Based on consultations conducted to date no residents have raised any issues or concerns related to visual impacts.
In any wind farm shadow flicker presents the potential for localised visual nuisance to residents. As stated the closest residents are 1.2 km away from the nearest turbine. Within north-western Europe a standard guide used to indicate the likelihood of shadow flicker nuisance is based upon the equivalent of ten times the height of the turbines measured from the nearest turbine to the receptor. Given Bulgaria’s longitude is more southerly than north-western Europe this distance is expected to be less that 10 times the rotor height and in the range of 1.0-1.4 km and thus anticipated to be largely out of the range of the nearest households. However with turbines reaching a height to tip of under 150m it is evident that some incidents of shadow flicker may be possible, although they are likely to be rare. AGE have committed to complete a detailed shadow flicker assessment and, based on findings, if necessary, amend the turbine layout to eliminate unacceptable impacts. These results will also be disclosed to affected local communities as part of ongoing liaison defined in the EMMP.
The above listed issues of noise, visual impact and shadow flicker will be a particular focus of AGE during the second round of consultation defined below.
Neither AGE nor it’s contractors will employ armed security; security guards or services will be employed by AGE and their contractors, and these guards will receive training consistent with PS4 to ensure any response to threats to the project/personnel is in proportion the threat. Contractor contracts will contain a requirement to comply with this requirement.
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management:
The site is located in or under the Via Pontica migration corridor (or flyway) 3 km from the coast, but does not comprise a known breeding or resting area for migratory species. Legal and local recreational hunting occurs to this day in the project area, thus while the site is seasonally located within a flyway, from the terrestrial perspective the landscape has been intensively managed, exploited and cultivated for many decades.
Consisting of agricultural land, unpaved secondary and tertiary roads, and shelter belts (plantation forest belts forming narrow corridors along agricultural fields), the area maintains low biological diversity. A variety of common local mammals, reptiles and amphibians (non of which are endangered) would experience short term disruption during construction but are expected to rapidly and fully recover at completion. Given the intensive and historic agriculture in the area and hunting, there is periodic disturbance to these creatures that has been occurring consistently over recent decades. The habitat is thus of low value and is commonly found in the region.
Resident bird species occur on site, though as with the other animals, the species diversity is low and insignificant. These birds are found either in the shelter belts, on site or sown agricultural fields. None of these is a IUCN Red Listed or EU endangered species and impacts on these is not expected to be significant.
The species of bat occurring on site generally fly below the minimum rotor height of 25 meters. Because bats are protected in the EU and given that available European literature and experience with regard to bats and wind farms is limited, AGE, in order to ensure there are no significant impacts on bats or resident birds, will establish, as defined in the EMMP, a monitoring program to verify that the predicted level of impacts are not significant, and to assess, whether additional specific mitigation measures are necessary. Such measures may include expansion of shelter belts as necessary, avoidance of construction at night time, fencing off specific areas of shelter belts to protect habitat and animal species where appropriate; siting of construction infrastructure to avoid larger shelter belt areas, and limits on vehicle speeds on site.
Impact on terrestrial and/or local fauna and flora are thus either temporary, not significant and can be easily mitigated.
The general area in which the project is located is considered critical as a flyway for migrating birds, and, based on newly observed behavior in January 2008, possibly important to a population of geese as a wintering place. Large numbers of migrants are known to pass through the area although the migration volume over the project site is highly variable, both in terms of total numbers and routes used. The intensity of the migration over the site is expected to be high when winds are predominantly westerly; data indicates that this does not occur on a regular or annual basis. With respect to migratory birds the SIR considered and assessed the following factors:
- collision risk analysis, using a widely accepted model;
- a more extensive literature review;
- clarification of how the proposed turbine shutdown system would operate;
- specification of a more detailed monitoring scheme; and
- cumulative ornithological impact assessment (defined as all existing, permitted and wind development under construction).
A comprehensive range of baseline bird surveys has been undertaken for the purposes of the EA process. Commencing in 2004, to date seven seasons of migration surveys have been completed (four for the autumn migration and three for the spring migration). Using the baseline data for the project site, collected over a period of 3 years by the Bulgarian Academy of Science (BAS) and collated for the purposes of the original EIA, and data recorded by the BSPB for the wider area in 2004 and 2006, a quantitative Collision Risk Assessment (CRA) was undertaken. This CRA was done using the Scottish National Heritage (SNH) model, the SNH collision assessment model is the most widely used and accepted model in the UK and is widely accepted by leading bird organisations (such as BirdLife and the RSPB). It should be noted that there is no established EU, Bulgarian or international model and thus SNH was deemed appropriate and used for the project. This model assumes that if mortality is over 1% of the normal mortality of the individual species’ European population then the impact is significant. Based on the CRA, as defined in detail in the SIR, the project is not expected to exceed this 1% threshold for any migratory species of bird.
The CRA considered worst case parameters based on inclusion of all data (i.e., BAS and BSPB) as well as input of cumulative affects associated with other wind farms. The focus was on the significant species found in the flyway:
- White stork
- White pelican
- Honey buzzard
- Lesser spotted eagle
- Pallid harrier (European endangered list)
- Great spotted eagle (European endangered list)
- Imperial eagle (European endangered list)
- Saker Falcon (IUCN Red List Threatened Endangered and European endangered list)
Whilst the CRA predicts far below 1% mortality for these bird species, there is nonetheless incremental mortality of endangered species associated with wind development in the area. For the above listed endangered species the cumulative (i.e., wind farms permitted, operating or under construction) impact is as follows:
- Pallid Harrier - 1 individual in every 10 years
- Great Spotted Eagle - less than 1 individual in every 10 years
- Imperial Eagle - less than 1 individual every 10 years
- Saker Falcon - less than 1 individual every 10 years
This loss for these species is thus expected to be under the SNH 1% threshold and is thus not deemed to affect species viability, and the SIR therefore concludes that the project and cumulative impact is not significant for these species or indeed any other species of migratory bird. Whilst the model predicts a number of 1 in 10 years for the Pallid Harrier, actual collisions are expected to be far lower.
Based on the data and CRA, the majority of potential cumulative collisions are attributed to the White Stork, with between 15 and 86 collision per year predicted from the BAS and BSPB data respectively, combined the figure is approximately 93 collisions per year. Whilst such numbers are not considered significant in population terms, suitable mitigation is required in order to minimize bird mortality. The assessment also considers the unlikely event for large numbers of soaring migrants passing through the Project site at rotor height and/or resting within the wind farm site during extreme weather conditions. Under this scenario, whilst again the predicted number of collisions would not be considered significant in population terms, it serves to reinforce the requirement for suitable mitigation. Information from other wind farms in Europe, e.g., Tarifa in southern Spain, is detailed in the SIR. Tarifa is located in the West European Flyway, real data from this operation indicates collision rates of a handful of non endangered storks every year. The model must thus be viewed as simply that, a model of projected impact in the worst case scenario.
In addition, based on data obtained through the Wildfowl and Wetlands Trust (WWT) and the BSPB; a population of wintering geese, including white fronted and red breasted geese (RBG), were observed in the project area during January 2008. The exact number of geese observed and their species mix is not definitively known. The presence of these species in the area in any significant numbers is considered as a new phenomenon as there is no substantive historical data that indicates significant numbers of wintering geese have consistently habituated the area. Whilst the RBG is an (IUCN Red List) endangered species, historical data provided by the WWT, BSBP and Birdlife indicate that the RBG is not common to Kaliakra (the project area) and that the RBG winters primarily in Romanian and Bulgarian fresh water lakes, the closest of which is 30km north of the project site at Shabla Lake. Adjacent to Shabla Lake there is an existing Natura 2000 site and wheat crops on which the RBG feed. Crops in Kaliakra have in recent years shown a shift towards biofuels, this is makes it less likely that geese will return and winter in the project area as it is wheat (and other food crops) which attracts them. Accordingly, as summarized below, the project’s bird monitoring and shutdown scheme will take into account this new information and AES is firmly committed to adjusting the plant shutdown to ensure impacts on RBG (and indeed on other migratory and wintering birds) are not significant from a mortality or habitat perspective. Measures will also be incorporated into the Project design to ensure that any displacement which may occur in relation to these species is not significant and this will be captured within the EMMP.
The overall assessment confirms that mitigation in the form of turbine shutdown at times of migration and wintering activity, and measures to offset potential disturbance are suitable measures to employ to reduce collision risks and disturbance effects. The shutdown system will include a combination of human observers and radar systems to give early warning of approaching migrant and wintering flocks. Using both of these will be essential to enable a full assessment of the oncoming risk to be assessed in the field and the appropriate action taken swiftly. The main period of concern is the August to September autumn migration period, and possibly winter months (to account for potential wintering geese), so it is proposed that the shutdown system will operate during these periods.
A bird-tracking radar system will be set up at an appropriate location giving the radar a view over the main migration route into the site and will include a horizontally-mounted surveillance radar to track bird flight paths and a vertically-mounted radar to measure flight heights. Initially it is proposed that the turbines will be shut down whenever there is a major migratory movement within 2km of the site. This ‘major migratory movement’ has been defined as the number of flights at which a bird collision with the turbines becomes likely. For the key target species, approximately 1 collision was predicted per 2,000 flights through the site so the proposed initial precautionary trigger has been set at 1,000 birds approaching the site. This system will be refined with experience and observations on site.
In addition to the turbine shutdown, monitoring will be undertaken before, during and after construction. The proposed monitoring will have several key components, as follows:
- measurement of bird use of the area within the wind farm and at a suitable reference site, to investigate disturbance effects throughout the year (including breeding surveys);
- measurement of bird flight activity through the wind farm site (including flight height) through the year. This will be over a sufficiently wide area to cover the wind farm site and at least a 2km buffer;
- detailed monitoring of bird flight activity during the August to September autumn migration period (as part of the turbine shut-down program);
- monitoring of collision victims around the wind turbines;
- use of data collected during (2) - (4) to update the collision risk model and test its output; and
establish, where possible, links with other bird monitoring programs at other wind farms to facilitate data-sharing and a wider-scale analysis of effects.
Further details of the proposed monitoring scheme are given in the SIR. One further measure will be adopted which consists of marking the overhead lines with bird deflectors to increase their visibility. This will further help to avoid collision risks.
The ornithological assessment concludes with an assessment of cumulative impacts i.e. those that could arise as a result of the combined impact of other wind farm developments in the region. It is predicted that cumulative impacts are not significant. Moreover, the Project, with the implementation of the proposed turbine shutdown system, would result in approximately a 10% contribution to the overall bird collision risk. This is neither significant in itself nor contributing to a significant cumulative effect.
Whilst, collision risk will inevitably be a feature of a wind farm at this location, the mitigation proposed will enable that risk to be managed in such a way that it should be neither significant in bird population terms, nor sufficiently high such that it becomes an issue through the level of bird mortality in terms of animal welfare. The SIR thus states that that the Project or cumulative impacts will not have any material impact upon the viability of the Via Pontica migration corridor.
It should also be noted that the EA was also undertaken in accordance with EU Guidance on the Assessment of plans and projects significantly affecting Natura 2000 sites (Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC), relative to the proposed Natura 2000 Special Protection Area to the south of the site. As the Project does not lie within its boundaries, and impacts upon both breeding bird species and migrating species are considered not likely to be significant, no significant impact upon this site is anticipated.
Based on the above information and the SNH model, even though the Via Pontica is critical to the survival of migratory species, impacts on any single migratory birds species are not predicted to be significant and will thus not affect the species viability.
- PS8: Cultural Heritage:
The project site is known to contain Thracian burial mounds and other Grade B settlement sites as defined by the National Institute of Monuments of Cultural Heritage (NIMC). During EIA completion the Director of the Town History Museum (of Kavarna) was retained as part of the EIA team. Based on review of existing archaeological maps and surveys, consultations with the NIMC, and the current proposed turbine locations, it is an operating assumption or goal that direct impacts on all known sites can be avoided. To address potential direct, indirect and chance find impacts on these resources field reconnaissance surveys will be undertaken prior to construction to accurately identify the extent of known resources on site and to assist with the micrositing of turbines and other facilities (e.g., road expansion) prior to construction. Existing roads and tracks will be expanded as necessary to eliminate the need for any new roads thereby minimizing the chances of disturbing archaeological sites.
As defined in the EMMP, a chance finds procedure will be established and contractors will receive training on this procedure and the relevant authorities will be on call and will be consulted during construction. Furthermore AGE will be required to stop work for chance finds, alert authorities, and allow authorities to inspect sites, and if necessary, excavate the respective site prior to re-commencing construction. Based on the excavations or inspections authorities may require project design changes. AGE has furthermore agreed to fund any excavation required of these sites.
