CWP is committed to proactively addressing social and environmental aspects associated with its projects and operations. CWP’s subsidiary construction company, which will undertake construction of the 8th Ganhekou Project as well, has an integrated quality, environment, occupational health and safety management system certified to ISO 9001, ISO 14001 and GB/T 28001 standards. CWP will require both its O&M subsidiary and the Project Company also to put in place an occupational health and safety management system certified to OHSAS 18001 standards. CWP’s present approach to managing social and environmental performance needs to be upgraded for it to become consistent with the IFC Performance Standards. As part of the Environmental and Social Action Plan (“ESAP”) agreed with IFC, CWP will implement measures, discussed here, so as to ensure that its projects and operations result in outcomes consistent with IFC Performance Standards and applicable IFC EHS Guidelines.

Further, CWP will, as part of the management program under the SEMS (applicable also to its subsidiary companies) develop and implement procedures to:

- review and screen projects it bids/applies for either as an owner/developer, EPC, construction or O&M company. The review of projects under the screening procedures will lead to the following outcomes: (a) the acceptance of contracts in which CWP’s environmental and social standards (including those of IFC’s Performance Standards 1 through 8) can be met; and (b) the re-evaluation, renegotiation, or decision on rejection of contracts that cannot be implemented according to CWP''s requirements.

- ensure that the environmental impacts associated with its projects and operations, are managed in accordance with good international industry practices including IFC Environmental, Health and Safety Guidelines and result in outcome consistent with IFC’s Performance Standard 3 provisions. Site specific pollution prevention and mitigation measures associated with each of CWP’s projects and operations will be identified and addressed through the social and environmental assessment and social and environmental management plan process.

- identify and mitigate community health, safety and security impacts in accordance with IFC’s Performance Standard 4 provisions. Further, CWP will implement measure to minimize the risk of exacerbation of community exposure to disease due to influx of labor or due to changes in land/hydrologic or other terrestrial regimes. Additionally, where an influx of labor is expected, CWP will provide or require its contractors to ensure that: in the labor accommodation appropriate facilities and amenities are provided including housing, toilets, washing and cleaning water, potable drinking water and cooking fuel; treated sanitary waste water meets IFC requirements prior to discharge; and potential host community impacts on account of influx of labor are assessed and managed.
- based on the project specific social and environmental assessment, implement appropriate measures including: material movement planning; barricading of excavated areas; safety signage; provision and use of appropriate personal protective equipment; illumination; mitigation of shadow flicker, glint and ice throw; to reduce fugitive emissions; restriction of night time activities to low noise generating work; monitoring and mitigation of ambient air quality as also noise impacts; provision of aviation light (night sighting) and paint/markings (for day sighting); adherence to offset from property line criteria; wind turbine cluster design with uniform size, design, shape, colors, painted in a non reflective neutral color to minimize adverse visual impact; and other measures to mitigate the risk of accidents for general public during construction and operation. In transmission line route planning, CWP will take into account risks and impacts including electrocution, as applicable. Further, for communities’ resident in the vicinity of the transmission line, CWP will implement a general awareness program detailing dos and don’ts to minimize electrocution risk. CWP will prepare and implement an onsite and offsite Disaster and Emergency Management Plan at each of its project sites.

- ensure that land acquisition resulting in involuntary resettlement, in all projects undertaken by CWP and/or its subsidiary companies, including impacts due to involuntary right of way acquisition/ restrictions in land use for associated facilities like transmission Lines or access roads and/or crop loss during construction or operation phases are mitigated in a manner consistent with IFC’s Performance Standard 5. Further, in cases, where any of CWP’s projects is likely to materially transform, degrade or impact lands and resources on which indigenous peoples (“IP”) are dependant, CWP will ensure that the social and environmental assessment and mitigation is undertaken in accordance with IFC’s Performance Standard 5 & 7 provisions.

- minimize and mitigate impacts on bio-diversity in a manner consistent with IFC’s PS6 provisions, particularly when its project sites/facilities are located in, pass through or are in the vicinity of: (a) critical natural habitat; (b) protected areas including wildlife sanctuary, national parks, reserved forests, breeding grounds of key species and archaeological monuments; and (c) other eco-sensitive areas like marine environment, rivers, streams and wetlands with aquatic or other flora-fauna. Further, CWP will, develop and implement a chance find procedure including for finds of archaeological (prehistoric), paleontological, historical, cultural, artistic, and social values.

CWP has put in place a corporate safety and environmental organization in the design institute staffed with government certified safety and environment professionals. Further, CWP puts in place, at each project site and in its operating plants, suitably trained professionals for management of safety and environmental aspects. Typically, at each project site a qualified third party is engaged for monitoring and supervision of safety and environmental aspects during construction. Further, during operation stage, appropriately trained professionals form part of the Occupational Health and Safety and Fire Safety committees led by the site director.

CWP will, under the corporate wide applicable SEMS, further strengthen the capacity of the social and environmental organization by implementing procedures for: (a) engagement with affected communities in accordance with IFC Performance Standard provisions; (b) ensuring that contractors meet relevant provisions of CWP’s SEMS; (c) environmental, occupational health and safety training of employees and contract workers; (d) recording, investigation and reporting of social, environmental, occupational health and safety incidents including those involving contractors’ labor; (e) periodic monitoring and assessment of social, environmental, occupational health and safety performance; (f) internal and external audits and implementation of corrective action; (g) management review of the management system; and (h) periodic reporting of social, environmental, occupational health and safety performance to CWP’s Board of Directors, regulators and investors.

The 8th Ganhekou Project

The Project Company has, to meet regulatory requirements, completed an Environmental Impact Assessment (EIA) prepared by a third party for the 8th Ganhekou Project, which has been approved by the provincial authorities. The EIA addresses key social and environmental impacts associated with the 8th Ganhekou Project construction and operation including those pertaining to: noise; air quality and ambient conditions; water and wastewater; solid waste; electromagnetic fields; ecology; avifauna and bird migration; glint and shadow flicker; vehicular emission; hazardous materials and waste; soil erosion; cultural heritage; and monitoring, reporting and supervision. The Project Company will implement additional mitigation/management measures consistent with good international industry practices including those discussed below to construct and operate the 8th Ganhekou Project in accordance with IFC Performance Standards. The responsibility for implementing mitigation measures delineated in the environment management plan lies primarily with the Project Company. However, the construction company will be contractually required to ensure adherence to the environment management plan. Also, the construction company will be required to engage a government certified third party for monitoring and supervision of implementation of the environment management plan.

PS 2: Labor and Working Conditions

CWP currently has about 816 permanent employees on its including its subsidiaries rolls. The employee strength is expected to increase with increase in the number of projects under implementation as also due to the expected increase in the EPC and O&M operations. Typically at a project site during O&M phase about 25 – 30 persons are employed and at the 8th Ganhekou Project site also about 30 persons will be employed during the O&M stage. During construction at the 8th Ganhekou Project, about 300 workers are expected to be engaged at the project site. It is expected that most will be from nearby districts.

CWP has a Human Resource (HR) Policy and Procedure including for recruitment and induction; reward and disciplinary procedures; and labor contract management. The HR Policies and Procedures are applicable to CWP, its subsidiaries and include in its scope direct employees. Terms of Employment and Working Conditions are detailed in the Labor Contract that every direct employee signs with CWP or its subsidiary company. The HR Policies and procedures were formulated in consultation with the employees, are available on CWP’s intranet and are communicated to all new employees during induction. While the internal audit function, as part of its work program, seeks employee feedback, CWP has an independent/third party managed process for confidentially seeking employee feedback also. However, this confidential feedback process is a onetime event and a formal grievance redress mechanism needs to be put in place. Several provisions and scope of the HR Policies and Procedures need to be upgraded to make them consistent with IFC Performance Standard 2 provisions including e.g. the need to appropriately address working conditions for indirect employees and sub contract worker; upgrading provisions of disciplinary procedure; need to include a formal grievance redress procedure etc.. CWP will commission a third party to undertake a comprehensive review of its HR Policies, procedures and practices for conformance to IFC Performance Standard 2 provisions. Further, CWP will, based on the findings of the third party review, implement measures to make its HR Policies, procedures and practices consistent with PS2 provisions.

While construction work at the 8th Ganhekou Project will be conducted during daytime, O&M is undertaken in 3 shifts. CWP typically provides adequate accommodation to its O&M employees (2-3 persons to a room) with all basic amenities, and facilities including food and recreation. The same standards will be adhered to at the 8th Ganhekou Project site as well. During construction at the 8th Ganhekou Project site, CWP will construct temporary worker accommodation. In the worker camp/accommodation, CWP will provide adequate living conditions including appropriately sized rooms with basic amenities; electricity; potable water, mess facilities for food; provision of toilets and bath including separate toilets and baths for women workers/family members of workers; appropriate sewage disposal through septic tank and soak pit; fire prevention and control; and primary medical care for all workers engaged at site.

CWP adheres to the state grid safety regulations as regards procedures for management of occupational health and safety risks including in substation O&M and transmission line O&M. CWP has in place procedures for safety in turbine operation and maintenance. CWP has safe practice procedures and facilities including appropriate personal protective equipment for working at height, electrical safety, fire prevention and control, for working in extremely cold conditions and emergency preparedness and response. The workers are trained on occupational health and safety. Each site has a safety organization and a fire safety organization headed by the site’s project director. In each shift, a certified safety officer and a safety co-ordinator is deployed. The 8th Ganhekou Project construction company] has occupational health and safety systems certified to GB/T 28001 standards and the Project Company will also implement a OHSAS 18001 certified occupational health and safety management system. During construction about 15 safety staff comprised of 7 government certified safety professionals and 8 safety-co-ordinators will be deployed. All of the 300 workers will be provided occupational health and safety training and will have to pass a safety test. While several first aiders will be available at the 8th Ganhekou Project site, CWP has tied up with a local hospital in the event of an emergency/urgent medical care. CWP will maintain a fully equipped ambulance at site during the construction period for responding to medical emergencies.

Further, CWP will as part of the contract, require the O&M company to implement: (a) an occupational health and safety (OHS) policy acceptable to CWP; (b) site risk management and emergency response plans; and (c) report on OHS incidents. CWP will implement procedures to monitor the social and environmental performance of the Project Company for the 8th Ganhekou Project and ensure adherence to Performance Standard provisions.

PS 3: Pollution Prevention and Abatement

The 8th Ganhekou Project is a renewable energy project, which will contribute to GHG avoidance. While material impact on ambient air quality is not expected on account of the 8th Ganhekou Project during operation phase, the Project Company/construction company will implement measures to minimize dust during construction period including: management of fill/excavated earth, construction rubble; emissions from batching plant; handling of cement; dust suppression measures; vehicular movement planning, paving/hardstanding vehicular movement areas; minimizing time for which excavated earth is left loose at site; avoiding excavation during windy and rainy season; and other measures for minimization of fugitive dust emissions. Potential for fugitive dust and soil erosion is high also on account of the dry weather, prevalent high wind conditions, high evaporation rate and sand/soil particle size of <0.25 mm at the site. The Project Company proposes to implement soil and water conservation measures during construction and operation phases to minimize soil erosion on account of the 8th Ganhekou Project.

Temporary increase in ambient noise level is anticipated on account of use of earth moving and other construction equipment and increased traffic for material movement during the construction phase. In addition to ensuring that the equipment is well maintained and has appropriate mufflers, the Project Company will ensure that the construction work will be carried out only during day time and no noise generating equipment will be operated at night. In addition to ensuring use of appropriate personal protective equipment while operating/working in the vicinity of such equipment, the construction company will be required to reduce exposure of its operators/workers to high noise generating equipment. Noise from individual turbine during operation phase decreases to 48 dB(A) at a distance of 200 m from the turbine. The Project Company is proposing locating turbines in a grid of 9D x 6D dimensions, where D is the rotor diameter, to mitigate risk of cumulative noise impact on account of the 8th Ganhekou Project. Labor camps/worker accommodation will be located in a manner as to minimize exposure to noise from construction site or from the wind turbines during operation stage. Further, there are no other sensitive receptors in the vicinity of the 8th Ganhekou Project site.

The Project Company proposes to consume 150 m³/day of construction water and 50 m³/day of living water/water for domestic purposes. The water, for construction and for domestic consumption during both construction and operation stages, will be sourced from a deep well. The water will be tested for potability before being used for domestic purposes. Construction waste water (from batching plant equipment cleaning, transit mixer washing and other equipment washing/maintenance work) will be disposed through a settling cum evaporation tank in view of the high evaporation rate at the site. The Project Company will put in place a septic tank to treat and dispose the domestic sewage both during construction and operation stages. The Project Company proposes to use the treated sewage on premises for irrigation purposes.

While construction will be generally avoided during very high wind and rainy periods, in any case appropriate mitigation measures to minimize erosion will be implemented. Surplus excavated earth will be used for road and area leveling, back filling and for localized leveling work around the wind turbines. The Project Company will ensure that other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.) are collected, stored and disposed off to re-users or in government authorized debris treatment and disposal areas in Guazhou.

Hazardous materials (transformer oils, dielectric containing material, paints, batteries etc) and hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels etc) are expected to be generated during construction and operation. However, the Project Company will ensure that hazardous material and hazardous wastes handled/generated at site (both during construction and operation) are: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and disposed off through entities authorized to handle and dispose hazardous wastes.

The Project Company will ensure that: transformers do not use PCB containing oils; and ozone depleting substances banned/phased out under Montreal Protocol are not used. Material electromagnetic field impacts are not anticipated on account of the 8th Ganhekou Project and its associated facilities. The wind turbines will be provided with aviation light (night sighting) and paint/markings (for day sighting); and wind turbine cluster will be designed with uniform size, design, shape, colors, painted in a non reflective neutral color to minimize adverse visual impact.

PS6: Biodiversity Conservation and Sustainable Natural Resource Management

A conservation zone, designated at national level, is about 1 km from the project site. In addition, The Gansu province has several Important Bird Areas (IBAs), the nearest of which is approximately 100 km from the 8th Ganhekou Project. However, the 8th Ganhekou Project site: (a) does not fall within known, documented flyways of international or domestic migratory birds; and (b) is not a known breeding or nesting site for important bird or animal species. The Project Company will however partner with an appropriate organization to assess, monitor, map and where required mitigate adverse conditions/impacts in accordance with PS6 provisions: (a) potential impact of the 8th Ganhekou Project on the neighboring conservation zone; (b) presence and/or the nearest flight corridors for international or domestic migratory birds; (c) evidence of nearest nesting/breeding sites; and (d) evidence of bird hits from existing wind turbines. The Project Company will, during construction and operation put in place measures to minimize removal of any existing vegetation, which is already sparse desert scrub/bushes.