PS1: Social and Environmental Assessment and Management Systems
Environmental and Social Impact Assessments (ESIAs) were undertaken for both the hydropower and transmission line components of the Paravani project. The hydropower ESIA was started in 2008 and completed in late 2009, whilst the transmission line ESIA followed in late 2010, once a final decision had been taken on linkages to the Georgian/Turkish grids and routing information was available. A combined Environmental & Social Action Plan (ESAP) has been compiled covering both components and is disclosed with this ESRS. The ESIAs were completed in a form required to meet Georgian regulatory requirements initially, and then expanded to meet EBRD/IFC requirements. A Non-Technical Summary and a Stakeholder Engagement Plan have also been produced and are attached.
Alternatives analysis was included in these documents, including review of technical, intake, tunnel, penstock, powerhouse building, transmission line routing and alternative power generation alternatives. The combined ESAP will form the basis of the Project’s environmental and social management program and system. As per the ESAP, key construction phase Environmental & Social Management System (ESMS) procedures, such as an OHS implementation plan, blasting procedure, waste management procedure and community liaison procedure, will be developed prior to the commencement of the main construction works. Operations phase ESMS procedures will be developed prior to the commencement of HPP operations.
An Occupational Health & Safety (OHS) site representative has been appointed by GUE as part of the site services contract. In addition, an Environmental site representative will be appointed to oversee implementation of the ESAP. All major site construction contractors will be required to retain qualified environmental and/or OHS personnel to oversee ESAP implementation; key requirements will be built into the construction contracts. GUE’s site OHS and Environmental representatives will monitor site activities against ESAP requirements, and GUE will appoint a reputable environmental consultancy to undertake six-monthly environmental monitoring and reporting during the construction phase and annual monitoring during the first 2 years of operation, in order to provide assurance that agreed ESAP performance levels are met.
Trans-boundary effects
The project is located on the Paravani River, a tributary to the Mtkvari (Kura) River, which flows from Turkey, through Georgia and into Azerbaijan before flowing into the Caspian Sea. IFC will assist GUE with the notification of Azeri officials, via the relevant Executive Director’s Office. Based on the results of the ESIA, adverse downstream impacts on the Mtkvari River as a result of the construction and operation of the Paravani HPP are likely to be minimal. The volume of flow entering the Mtkvari River will remain unchanged, though much of the flow will enter the Mtkvari approximately 1.5 km upstream of the current confluence with the Paravani River. Given the design of the Paravani HPP, i.e. with a low weir and minimal storage area, water quality changes in the Mtkvari River during operations are likely to be minimal. The weir has been designed with a fish pass and a minimum environmental flow will remain in the by-passed reach at all times; according to available information, the downstream ecological flow that will be left in the bypassed reach will be sufficient to maintain the ecosystem viability for identified species. This will be monitored and adjustments will be made if necessary. Potential cumulative impacts are discussed below.
Cumulative effects
Paravani HPP is currently the only HPP on Paravani River certain to proceed, though old studies indicate potential for up to four more HPPs upstream, three of which (Arakali 18 MW, Abuli 12.5 MW, Akhalkalaki 14.5 MW) may be developed by a Turkish firm according to recent (February 2011) press releases. A fourth, much smaller (Poka, 0.5 MW) HPP was also identified in the original studies, but there is as yet no indication that it will be developed. All of the proposed HPPs would theoretically be run-of-river schemes with limited storage, although two would feature embankment dams of 30-40 m in height. A Cumulative Impact Assessment was publically disclosed in 2010 for HPPs on the Mtkvari River and its tributaries in Samtskhe-Javakheti (DG Consulting, 2010), including all the HPPs listed above and several others on the Mtkvari River and another tributary. The assessment provides a basic description of each project, describes the baseline environmental and socio-economic conditions of the study area and presents an analysis of key potential cumulative impacts. It also recommends cumulative impact management and monitoring actions and monitoring requirements, and contains suggestions for basin-wide management actions to be taken by agencies of the Government of Georgia.
Without key design information or ESIAs for the newly announced projects, it is not feasible to produce a more meaningful cumulative impact assessment than already exists. A technical Annex has been included in the project disclosure documentation that considers potential cumulative impacts, focusing on a qualitative review of the key predicted cumulative effects of multiple HPPs on the Paravani River, providing a set of associated monitoring requirements and a recommendation for future cumulative assessment work if and when key design, environmental, social and scheduling information becomes available for the other proposed Paravani HPPs.
Based on existing data it seems likely that the key cumulative risks would include the following:
Changes to hydrology/flow characteristics in the by-passed sections of the river
Changes in water quality associated with construction (sedimentation) and operations (sediment load, temperature)
Changes in aquatic habitat and aquatic life related to barriers to migration (new weirs, dam walls, and turbine halls) and diminished water availability in by-passed reaches.
In mitigation, a minimum environmental – or ‘sanitary’ - flow will be released to sustain downstream ecological function and both the quality and volume of releases will be monitored prior to, during and after construction of the weir. Similar releases will be required by law for any upstream schemes. More detail on the environmental flow for Paravani HPP is provided in the Performance Standard 6 section below. Monitoring of the health of the aquatic ecosystem will be undertaken to confirm that the sanitary releases are sufficient and to track any actual ecological impacts. Paravani HPP weir design will be reviewed to ensure adequate fish passage at all times and to reduce potential fish mortality. Similar monitoring and design review is recommended for potential future upstream HPP schemes, although this does not fall within GUE’s control. The results of Paravani HPP ecological and flow monitoring could represent an important input to recommended future cumulative impact studies on the Paravani River.
PS2: Labor and Working Conditions
This is a Greenfield project which will be constructed by contracting companies from a number of countries including Turkey and Georgia. As such, there is currently no Sponsor workforce present on site. Construction will last approximately four years and will involve a mainly contractor workforce of around 200 persons. During operation the company will employ 25-30 persons.
As indicated in the ESAP, GUE will develop a Human Resources policy and associated procedures in accordance with EBRD/IFC requirements and Georgian labor regulations. These documents, or at least a detailed summary thereof, will be made available in writing to workers in their own language(s). Occupational Health and Safety (OHS) requirements will be built into project contractual requirements and will be monitored by the construction firm as well as by the owner’s HSE site representative and the HSE consultants. An OHS plan will be developed and implemented to guide all site activities during construction. This will include, amongst other things, job- and task-specific hazard analysis and controls, provision of personal protective equipment (PPE) and subsequent enforcement of PPE use on site, safety training for all personnel in their language, review and approval of contractor OHS plans (to meet the same standard as the GUE plan) and oversight of contractor OHS implementation, including mandatory reporting on key statistics. The OHS plan will be updated on an annual basis.
A formal grievance mechanism will be developed for employees and contractors prior to construction and information about its use will be disseminated to the workforce.
No child labor or forced labor will be used for project purposes.
There will be one main construction camp and three fly camps located near to the power house, intake and approach tunnel entry sites. Construction camps will be developed and maintained in a manner appropriate for its location and be clean, safe and, at a minimum, meet the basic needs of workers.
PS3: Pollution Prevention and Abatement
Potential emissions to air and soil will be limited to the construction phase. Air emission and noise modeling conducted during the EIA indicate that both construction and operations phase impacts will remain within acceptable limits and will not disturb the closest households. Dust emissions from site roads will be controlled by the use of water bowsers during dry periods.
Emissions to surface water will be most significant during in-stream construction of the bridge, weir structure and associated diversion works. The river will be temporarily diverted through a concrete lined canal on the right bank during these works. Some water will be required during tunneling operations, and there may be water make due to groundwater intersections in tunneling operations. Sedimentation ponds will be established to allow sediment to settle out before tunneling water is released. As described in the ESAP, GUE will oversee development and implement an erosion control plan to cover all construction activities prior to commencement of the main phase of construction. Periodic water quality monitoring will be conducted up- and down-stream of the weir site during the construction phase, as stipulated by Georgian Government requirements.
Operational emissions to water will include the periodic flushing of accumulated sediment into the river. Settling units will be constructed in front of the intake structure, in order to avoid turbine damage at the powerhouse. These units are designed to accumulate particles with a diameter greater than 0.3 mm, which will need to be flushed to avoid a reduction in power output. Flushing will be accomplished every 6 – 12 months during high flow periods; it is estimated that this will require 400-500 m3 of water, and will lead to short-term (2-3 hour) increases in turbidity downstream of the weir. The sediments to be flushed are not expected to contain pollutants. Runoff and storm water will be discharged into the river after settling. A water treatment facility will be provided at the powerhouse site. Mobile toilets will be provided during the construction phase, whilst septic tanks will be established for the operational phase. Drinking water will be taken from springs/wells located near the operation grounds; bottled water will be used during construction.
Power supply to the construction fly camps at the camps at intake, approach tunnels will be from diesel generators and the HPP site will be connected to the local 35kV transmission line. Explosives for tunnel construction will be stored in a secured and protected facility. The optimum quantity will be identified prior to commencement of works and no surplus material will be stored on site. Only qualified staff will be authorized to handle hazardous materials. Fuel storage tanks required during construction will be isolated away from traffic and provided with sufficient impermeable containment bunds to deal with large spills. Re-fueling operations and use of hazardous chemicals and solvents will only occur over impermeable surfaces. Spill clean-up/response procedures will be developed prior to construction, as detailed in the ESAP.
Spoil dumpsites will be located within designated areas and protected from erosion, as will be detailed in the erosion control plan. Other potential users will be encouraged to remove the spoil for other purposes, e.g. construction. Domestic and other solid waste will be collected in specially allocated areas on the sites with consideration of their type/properties. Spoil will be partly used for road rehabilitation/construction needs under the project. Potential users for the balance will be indentified. Waste wood (if any) will be used on site. Unusable waste will be disposed of at the nearest landfill under contract with the relevant municipal service. After completion of construction works, all waste material will be removed from the camp and construction sites. Sites will be restored to their pre-construction state, using stockpiled topsoil. Solid waste generated during operation will be very limited, given the relatively limited workforce. Domestic waste will be collected in containers, temporarily stored onsite and disposed of at the local landfill under contract with local service providers.
Greenhouse gas emissions from the project will be negligible during operations as there is a very small reservoir area within which the few existing trees will be removed during construction so as to avoid methane production from rotting vegetation. Currently, average CO2 emissions performance from the electricity generation sector in Georgia is 81 gCO2/kWh. This figure is relatively low following the demise of Soviet-era thermal power capacity and Georgia''s strategy of developing hydropower plants. The Paravani hydropower plant is predicted to generate 409 GWh per year. Compared to the current grid average, the project is expected to avoid GHG emissions by an estimated 32,000 tons CO2 per year.
PS 4: Community Health, Safety and Security
Dam safety is not considered to be a risk for downstream users due to the small (5 m) size of the proposed weir. As mentioned earlier, there are no settlements on the 13 km by-passed reach of the Paravani River below the weir site. The impoundment will be small (0.5 ha) in area and will be relatively inaccessible from local villages, which are located on top of the plateau, reducing the risks of accidental drowning. Due to the altitude of the site and nature of the weir, no risks associated with the proliferation of water-borne diseases are foreseen.
As described in the ESAP, procedures to protect public health and safety will be developed prior to commencement of major construction works and will include a traffic management plan for drivers and equipment operators, a procedure for notifying local communities about blasting operations, use of security personnel and signage to prevent unauthorized access to project sites, provision of notices to local authorities and local residents during construction of the transmission line and provision of hazard notices on power pylons. Appropriate camp rules will be established and enforced in order to minimize the potential for disruption of local communities by workers living on site during the construction phase.
PS5: Land Acquisition and Involuntary Resettlement
The project requires no physical displacement (relocation) of households for either of its two main components, i.e. generation and transmission. Land acquisition and associated economic displacement / compensation are discussed below for each component.
Generation: Land has already been acquired for the diversion weir site, access roads, construction camps and associated spoil disposal sites and the power house site. Most of the land required for generation infrastructure belonged to the State and was acquired some time ago. Limited acquisition of privately owned land was required for this component, notably one household located close to the powerhouse site with whom compensation arrangements and payments were finalized soon after GUE acquired the rights to develop Paravani HPP.
Potentially affected resources users downstream of the diversion weir site were identified during the ESIA process via public meetings and a site walk-over. These include the owners of two trout (fish) farms, one of which is located 1.7 km downstream of the weir site and the other 8 km downstream. The larger of the two takes up 1200 m2 of land whilst the other takes up 900 m2. The smaller of the two utilizes groundwater for its operations, i.e. does not rely on water flow, whilst the larger one utilizes a relatively low volume of water and is not expected to be affected by the proposed reduction in flow in the by-passed reach of the Paravani River. No other water users were identified along the 13 km by-passed reach below the diversion weir site.
Transmission: A decision on the route, type and location of the transmission line was made by GUE in late 2010, following which a site selection process and ESIA were launched. The ESIA concluded that the transmission line would not require physical displacement but that land acquisition and associated economic displacement and associated compensation arrangements would be required. No significant issues were raised by stakeholders during the ESIA consultation meetings pertaining to the transmission line, during which information was provided on the land acquisition process to be followed as well as pertinent safety information for future use of the right of way corridor. As such and consistent with IFC and EBRD requirements, a Land Acquisition and Compensation Plan is being compiled to document the magnitude of economic displacement involved, identify the households concerned, establish a compensation framework and describe the land acquisition and compensation process to be followed. This Plan will be publically disclosed by the Sponsors for at least 60 days prior to construction of the transmission line.
PS6: Biodiversity Conservation and Sustainable Natural Resource Management
The project does not impact any protected areas. Habitats to be impacted comprise a mix of natural and modified habitat. Vegetation in the vicinity of the intake structure is comprised of willow trees, assorted grasses and other flora associated with high mountain meadows. It has been somewhat impacted already by road construction close to the river bank. No endangered plant species were identified in this area. The plateau areas are mostly covered in grassland and will be only moderately impacted by road widening activities. Most of the access roads were pre-existing and are being widened somewhat for Project purposes, with topsoil stockpiled for future use. Tunneling spoil will be disposed of in selected areas adjacent to construction camps; these areas are rocky and have little vegetation cover. Approval for these spoil disposal sites has been obtained from the Georgian Government. The penstock will be constructed in a steep, rocky area devoid of tree cover and populated by scattered shrubs. No significant species were identified in the powerhouse area, which has been previously disturbed by human cultivation activity, although one nut tree species identified in the broader plot is listed as a Red Data species.
Although no rare or endangered fish species were identified in the Paravani River during the ESIA process, one species listed as vulnerable in the IUCN Red Data Book was identified, namely the Brown Trout (Salmo trutta fario). This species is also farmed on the Paravani River and elsewhere in Georgia, where it lives in both stagnant and fast-flowing environments, relying on the latter for breeding purposes. The other main fish species identified were Persian Gudgeon (Romanogobio persus), Khramulya (Varicorhimus capoeta) and Kura Barbell (Barbus lacerta). The low diversion weir will contain a fish ladder to allow fish to move up and down the river. As described in the ESAP, GUE will prepare and implement an aquatic monitoring exercise prior to construction in the river in order to establish a robust baseline for fish, aquatic habitat and water quality in the Paravani River up- and downstream of the proposed weir site. This will be followed up by a multi-taxa aquatic ecology monitoring programme to measure any changes in fish and other aquatic life and water quality in the Paravani River during construction and first 2 years of operations. If fish populations or ecosystem health are found to decline downstream of the weir, GUE will develop mitigation and offset measures using an adaptive management approach.
A minimum ecological flow will be maintained in the river at all times, constituting approximately 10 % of average annual flow, to protect aquatic ecology and allow downstream users (i.e. the trout farms) to continue operating as before. Flow monitoring will be conducted in order to ensure that the minimum ecological flow is being released, as described in the ESAP. The average annual flow rate of the Paravani River has been estimated as 16.5 m3/sec at the weir site, with the flow rate ranging from 6 to 30 m3/sec during the minimum and maximum flow periods. The hydrology of Georgian rivers in this region is relatively uneven, with a strong peak between mid-March and late June, i.e. Spring and early Summer each year. Hydrological analysis indicates that the actual flow of the Paravani River will be less than the average flow rate listed above for > 80 % of the year. Therefore the minimum ecological release mandated in Georgia can be expected to exceed 10 % of actual flow for 80 % of each year. During the dry/low season period, the ecological release will represent roughly 25 % of normal flow.
The project is a true run-of-river scheme with no meaningful storage capacity. As such, no significant changes in temperature or dissolved oxygen content are anticipated downstream.
PS8: Cultural Heritage
The area where the powerhouse and substation are being constructed falls within the buffer zone of the Khertvisi-Vardzia historic area, an 18 km section of Mtkvari River valley which was proposed by Georgia in 2007 as a future World Heritage site. It stretches from Khertvisi Fortress, located 1.5 km north of the proposed powerhouse site, upstream to Vardzia, a 12/13th century rock-cut monastery. Khertvisi Fortress is situated at the junction of the Paravani and Mtkvari Rivers on the top of a high rock formation, and is one of the best preserved forts in Georgia. Further south, beyond the powerhouse site, there are a series of rock-cut settlements, caves, churches, monasteries, burial sites and ancient settlements, some of which contain ancient mural paintings. The powerhouse structure itself will be out of line-of-sight from the Castle, according to studies undertaken during the impact assessment, and the transmission line has been routed in such a way as to avoid traversing the more visually sensitive valley area. Instead, it will be routed out of the valley on the same side of the river as the power house, avoiding any significant visual impact in the vicinity of the nearby Khertvisi Fortress which is frequently visited by tourists.
A field study by a cultural heritage specialist was conducted and concluded that the project, including transmission line, would not have any significant impact on cultural heritage, although a relatively small section of ancient river terracing will be destroyed during powerhouse construction. This sort of terracing is widespread in the Paravani and Mtkvari River valleys as a result of centuries of cultivation. In the unexpected event that earthworks uncover archaeological artifacts, a Chance Find procedure will be implemented such that constructive activities are temporarily halted whilst a qualified archaeologist is consulted.
At the request of the Cultural Heritage Agency, the Company provided a photomontage simulating the powerhouse and associated facilities, as well as architectural views of the powerhouse building, roofing and facing materials. The Company has incorporated into the design certain architectural changes requested by the Agency aimed at making the building blend into this historically important area. Moreover, as described above, due to the hill in between the power house and the fortress, the power house will be outside the view of view from the fortress.
