Environment, health and safety, and social development are at the core of SNPower’s and Cheves’s corporate vision and mission. Cheves has identified the project’s potential environmental and social impacts through multiple ESIAs and subsequent studies, and will have in place plans and procedures, as well as a team of professionals, to manage them. Relevant management plans will be further expanded and a supplemental environmental and social action plan (ESAP) has been agreed with the Company to strengthen mitigation and compensation measures to ensure that once implemented the project will comply with IFC’s Social and Environmental Performance Standards (PSs). The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow.
PS1: Social and Environmental Assessment and Management Systems.
Environmental and Social Assessment: This project has involved several Environmental and Social Impact Assessment (ESIA) processes dating back to 1997. The most recent and comprehensive ESIA for the project as it is currently conceived was presented by Cheves S.A. in 2006, and approved by the Environmental Division of the Ministry of Energy and Mines (General Energy Environmental Affairs Directorate - Dirección General de Asuntos Ambientales Energéticos - DGAAE) via Resolution RD N° 560-2006-MEM/AAE. When SN Power acquired the project in 2003, several engineering and design changes were introduced, resulting in an enhanced capacity of 168.2 MW from the original design of 158.6 MW. At the request of the DGAAE the updated Environmental and Social Management Plan (ESMP) was presented and approved in October 2008, via Oficio No 2754-2008-EM/AAE. Since this approval, there have been additional changes in project design (mainly the location of the tunnel exits and of camps, spoil deposits, quarries and other construction support infrastructure), and therefore new updated ESMPs have been prepared and will be presented to the DGAAE in early October 2010. Approval is expected in the fourth quarter of 2010, prior to initiation of main civil construction activities. The ESIA for the transmission line was also prepared, submitted and approved by the DGAAE in July 2008, via Resolution N° 312-2008- MEM/AAE.
The scope of the ESIAs included all project-related activities and ancillary facilities, as well as other relevant activities being developed outside the project’s direct area of influence. In addition to the ESIAs mentioned above, Cheves S.A. has commissioned complementary studies including, among others: gap analysis and supplemental ESIA study based on IFC’s PSs; assessment of thermal waters located in the project’s area of influence; and a complementary baseline study related to the minimum required river flow and corresponding mitigation measures. The Company will also conduct a safety assessment of 2 dams that operate upstream of the project since the 1950’s and 1960’s.
It should be noted that the development of additional capacity on the river is unlikely and there are no known plans by the Company or other developers of building other similar projects on the same watershed in the foreseeable future. In any case, should the Company decide to develop any additional capacity it will be required to conduct a Cumulative Impact Assessment.
All the ESIAs and complementary studies have concluded that Project-related adverse environmental or social impacts and risks are manageable. The Project’s above ground footprint is very limited since the main infrastructure will be underground. The transmission line’s footprint is mostly limited to transmission tower foundations and improvement and/or construction of new access roads that are expected to be minimal.
The ESIAs identified that, besides the typical impacts and risks associated with any new construction and civil works (e.g. air and noise emission, wastewater, solid and hazardous waste generation), the main potential environmental and social impacts are: (a) changes of river flow on a stretch of 17 kms; (b) potential increase of erosion processes mainly due to construction activities at construction sites, quarries and access roads; and (c) visual impact on landscape aesthetics resulting from the reservoirs, the reduced flow, and the transmission line. Identified potential socio-economic impacts of the project are associated with: (d) minimal economic displacement of 5 apple producers located on 2.5 hectares of land; (e) potential impact on tourism activities, specially associated with any potential disruption to thermal water sources in the area; (f) incremental risks associated to dam safety and emergency and community preparedness downstream; and (g) potential risks associated with the transportation and handling of explosives and hazardous wastes during construction. No impacts on water quality, quantity or irrigation channels and agricultural activities of downstream river users are expected.
Environmental and Social Management Program: SNPower and the Construction Contractor have in place corporate ESHS policies and procedures that, along with the ESIAs, local requirements and IFC Performance Standards, will guide the management of ESHS issues in this Project. The Company developed a Construction ESHS Management Framework for the Cheves project that includes the Company’s ESHS policies and an overview of the key ESHS issues and corresponding ESMPs, as well as arrangements with the Construction Contractor and monitoring activities to ensure compliance with Peruvian regulations and IFC PSs during construction.
Cheves S.A is in-charge of the implementation and enforcement of the ESMPs during construction and operation. The ESIAs outlined several ESMPs, including monitoring requirements, as well as contingency plans. Per the Construction Contract, the Contractor is responsible for developing and implementing all the environmental pollution and control measures as well as the occupation health and safety associated to the construction. Prior to initiating major construction works, the Construction Contractor will develop ESHS Implementation Procedures for the generation component based on Cheves’ ESHS Framework. These procedures will include, among other, specific procedures on: (i) Explosives Handling and Storage; (ii) Tunneling Health and Safety, and (iii) Contingency Management.
Cheves S.A. has also prepared an Integrated Social Management Plan (ISMP) to consolidate the social management plans developed through the different ESIAs and expanded its scope based on IFCs PS1, PS5 and PS7. The ISMP covers issues related to: (a) Company social policies, objectives and principles, (b) review of past community engagement efforts and description of future activities, (c) summary of land acquisition activities to date and relevant procedures and criteria, and (d) monitoring and evaluation arrangements.
Prior to project completion, Cheves S.A. will implement an ESHS Management System (ESHS-MS) for the project’s operation phase aligned with IFC’s PSs.
Organization: Staffing of the Client’s current ESHS team includes the Land and Permit Manager and the CSR and EHS Manager which report directly to the Project Director, and supervise a team of approximately 16 professionals in the field. Additionally, the Construction Contractor has a HSE Manager with reporting lines to the Construction Contractor Project Manager and Cheves EHS Manager, supported by a team of three professionals and an advisor.
Monitoring and Supervision: Several environmental and social monitoring programs were proposed in the ESIAs contemplating both construction and operation phases, including but not limited to (a) environmental quality monitoring during construction (e.g. camps and tunnel effluent discharges, water quality and temperature, noise and air emissions, soil compaction levels), (b) hydro-biological monitoring, (c) thermal water monitoring, (d) archaeological monitoring, and (e) vibration monitoring. In the case of monitoring of thermal waters and water quality/quantity, the monitoring activities will include Participatory Monitoring Program with the participation of representatives of the directly affected communities.
In the case of the Transmission Line ESIA, the proposed monitoring includes electromagnetic radiations and maintenance conditions.
The Company will further detail these monitoring programs and will have in place a comprehensive ESHS Compliance Assurance Procedure, specifying the way in which proper implementation of all ESHS requirements will be verified by Cheves ESHS staff.
Training and Reporting: In the ESHS Management Framework, Cheves presented a training program for employees and contractors, which includes general SN Power ESHS policies and ESMPs measures and procedures, as well as hazards identification and management, site inspections/ audits, and emergency situations identification and response. This ESHS Management Framework also proposes clear accident / incident reporting mechanisms, as well as the requirements for periodic ESHS compliance inspections and reporting to Cheves Management as well as local competent authorities.
PS2: Labor and Working Conditions.
Human Resources Policies: Cheves S.A. is a Special Purpose Vehicle (SPV) and only has a total staff of 21 people for which it has in place a Human Resources Policy based on Peruvian regulations, which are aligned with ILO’s Core Labor Standards, and it will be updated to reflect IFC’s PS2 requirements. On the other hand, civil works, electro-mechanical and other construction services associated with the power generation site will require the Construction Contractor and its subcontractors to hire 2,000 workers during the peak period and an average of 700 throughout the construction period. The construction of the transmission line is set to employ about 150 qualified workers and 150 non-skilled workers. These figures do not include outsourced labor for transportation, catering and other activities. During operations, the Cheves project will require a very limited workforce. Construction work will be undertaken in 2 daily shifts of 10 hours per shift, without exceeding the number of maximum hours per week allowed by Peruvian regulations.
Supply of unskilled and skilled local labor for the construction stage will be maximized to the extent possible through the implementation of a Local Hiring Program, while at the same time addressing potential induced impacts generated by influx of people looking for jobs at the site. To this end, the Local Hiring Program will include a strong communications component to manage expectations and to explain the recruitment process which will be conducted offsite in Project offices in Churín and through the project’s community engagement activities using direct communication channels. There will be no hiring at the gates of the construction site or campsites. The workers on the power house and tunnel construction will be housed mainly in the Pampa Libre camp located within the Project’s concession area. The Construction Contractor will be required to implement a Camp Regulations and Worker Code of Conduct, including provision of adequate accommodation facilities in all its campsites in accordance with internationally recognized standards (i.e. space standards for dormitories, minimum quantities of sanitary installations, maximum distances to installations, resting area requirements at construction fronts, among other key issues).
Specifications for labor have been included in Construction Contract and Cheves will ensure compliance of behalf of the Construction Contractor and its subcontractors with local requirements and IFC’s PS2 and that there are provisions not to engage any child or forced labor, grievance redress process for workers and freedom of association, among other relevant issues.
Occupational Health and Safety (H&S): SNPower Peru has an established H&S management system that is fully compliant with Peruvian legislation and with OSHAS 18001 guidelines. This management system is in place in all other Company investments in Peru. This management system applies to all construction and operation activities, and its basic principles include: aiming for zero accidents in all activities; supporting a company culture which puts people first by making H&S a primary objective in the planning, design, construction, operation and maintenance of power plants; ensuring that all employees are entitled to a working environment which is free from hazards to their health; ensuring adequate protection of personnel and assets against natural disasters and deliberate ill-intentioned acts (security threats) through a combination of preventive and emergency response planning measures; proactive planning, by promoting the use of safety analysis and the reporting of all unwanted occurrences; ensuring continuous improvement in H&S performance through the planning, implementation, execution and monitoring of the necessary programs and systems; ensuring that H&S laws and regulations that apply to activities are understood and adhered to; and ensuring open communication of H&S hazards and impacts of activities with own employees and other relevant parties. Additionally, the management system includes the following procedures: i) Procedure for Identification and Assessment of Safety Risks; ii) Procedure for Control of Chemical Products and Materials; iii) Vehicle Safety Procedure and Policy; iv) Vehicle Route and Itinerary Control Procedure; and v) Policy for Use and Maintenance of Personal Protection Equipment.
H&S requirements are also established in the Civil Works Conditions of the Construction Contract, and are also further detailed in the civil works specifications. However, the Construction Contractor will prepare a detailed H&S program before construction starts and will be based on Peruvian requirements, SNPower Peru’s H&S Regulation and the Construction Contractor’s corporate H&S policies and procedures adapted to the specifications of the project. Work in confined spaces (i.e. excavation tunnels, powerhouse cavern) will involve some risks that will required the Construction Contractor to develop a specific tunneling H&S procedure based on international best practices and including continuous air quality monitoring of CO, NO2 and SO2 in accordance with guidelines from the American Conference of Industrial Hygienists (ACGIH). Same type of specific H&S procedures and best practices will be required for the mounting and tensioning of electricity cables in the transmission lines.
H&S risks associated with the operation of hydroelectric schemes and maintenance of transmission lines are limited and can be effectively minimized through appropriate implementation of standard health and safety management practices.
PS3: Pollution Prevention and Abatement.
Pollution Prevention, Control and Monitoring: Some of the management measures during construction contemplated in the ESIA include: (a) measures to avoid soil compaction, (c) measures to mitigate atmospheric pollution due to dust, based mainly on periodic water spraying of unpaved roads and work areas and systematic maintenance of construction vehicles and equipment, (d) measures to minimize water quality impacts, consisting of erosion and sediment runoff control and prohibition of discharges of solid or liquid wastes directly on water bodies, (e) waste management program, establishing clear procedures for handling, classification, transport and final disposal of all solid wastes generated by the construction process, (f) revegetation program, establishing the requirements for reinstatement and bio-restoration of all areas to be directly affected by construction support infrastructure, such as construction camps, borrow pits, and others, (g) construction decommissioning procedures, establishing a comprehensive approach to ensure that all applicable construction close-out procedures are adequately implemented as part of the commissioning process and that no environmental liabilities are left behind, and (i) housekeeping and pollution prevention measures, as pertinent to minimize the risk of spills and other impacts resulting from use and handling of hazardous products.
In addition to monitoring programs typical for this type of operations, the following additional construction monitoring plans will be developed by the Company: (f) wastewater treatment plant effluent monitoring, as necessary to confirm compliance with the applicable discharge standards, (g) tunnel effluent monitoring (if any), also for confirmation of compliance with applicable parameters before discharge to the Huaura River, (h) vibrations monitoring, in order to ensure that vibrations from use of explosives are within acceptable limits at the location of nearby buildings, (i) building condition monitoring, as necessary to establish whether any Project induced damages to existing buildings take place.
Construction environmental mitigation measures proposed in the Transmission Line’s ESIA are similar in nature, albeit more limited in scope, focusing mainly on mitigation of water quality impacts, air quality impacts and soil impacts.
GHG/Climate: Due to Peru’s dependency on thermal generation, the current energy matrix of the country is relatively carbon intensive. The Cheves project will have a net positive impact by offsetting electricity sourced from fossil fuel power projects. The hydroelectric scheme has been registered under the United Nations Clean Development Mechanism (CDM) regime and will sell carbon emission certificates (CER) during the first 7 years of operation. The project is expected to reduce emissions of greenhouse gases by nearly 394,000 tCO2e per year. Since the reservoir will flood arid land and it has a short retention time, no GHG are expected to be generated from decomposing vegetation.
Emergency response: Cheves’s ESIAs provided general guideline for emergency response in the case of fires, accidents involving use of explosives, hazardous materials spill, worker accidents, traffic accidents, earthquakes, landslides and floods, and dam collapse. Additionally, the Transmission Line’s ESIA also includes emergency response requirements in the event of fires, spills, earthquakes, landslides and worker accidents. The Company will develop additional detailed emergency response procedures during construction activities, and detailed emergency response procedures for the operation phase.
It is noted that SN Power has in place a detailed Emergency Response Procedure (ERP) which is applied in all of its other hydroelectric investments in Peru. This ERP will be customized for Cheves and will include detailed emergency response in the cases of natural disasters, earthquakes, fire / explosion, severe traffic accidents, arrest of company personnel, kidnapping and/or disappearance of company personnel, diseases, epidemics or pandemics, bomb threats, terrorist action or threats, worker accidents, community violence and/or social unrest, hazardous products spills, floods, landslides, fall of people into water channels, and forest fires.
PS4: Community Health, Safety and Security.
Traffic and Explosives Transport and Handling: The primary risk to community health and safety identified for the Project is associated with traffic safety, vibration and dust generated by the transport of construction materials, equipment, and workers to and from the Project site during construction. Traffic during this stage will be significant and will be concentrated on the 30 km segment of the public access roads between the Huaura, Checras and Picunche dams. The most impacted areas will be Picunche, Puente Tingo, Cabracancha and Pampa Libre sectors, since in these areas there are people living along the road. Traffic interruptions will most likely be required on a daily basis throughout the tunnel excavation process, as necessary to transport explosives between the powder magazine and tunnel excavation fronts, but no related economic displacements is expected.
In addition to the basic mitigation measures identified in the ESIAs and corresponding environmental and social management plans (i.e. speed limits, dust control, etc), the client will prepare Road and Traffic Safety Management Plan based on best industry practices and IFC’s PSs. Similarly, it will develop a detailed Explosives Handling and Storage procedure based on Peruvian requirements and best industry practices, including communications of emergency response to potentially affected communities.
Risks Associated with Daily River Flow Fluctuations – Along the 10 km Huaura River segment between the tailrace tunnel discharge and the Picunche compensation dam, flows will vary significantly under certain operational conditions. This segment of the Huaura River is flanked by the unpaved public road on one margin and small agricultural parcels and other uses on the other, as evidenced by some cable crossings (oroyas). During minimal flow conditions, it is likely that crossing the river by foot will be preferred. As part of the Project’s ESHS Management System for operations the Company will implement warning procedures, including siren warnings and routine inspections of this segment, as well as specific community engagement procedures.
It must be noted that the Picunche dam and reservoir have been included in the project design to buffer this daily fluctuation during peak generation and avoid any potential issues and risks with farmers and communities downstream from the project.
Finally, the dams being built for the project are designed to ensure its safety even under extreme conditions (i.e. flash floods –huaycos- and earthquakes). In any case, in order to further address any related issues the Company will also conduct a safety assessment of 2 dams that operate upstream of the project since the 1950’s and 1960’s to analyze any potential consequences and probability of dam failure and designed appropriated risk management strategies.
PS5: Land Acquisition and Involuntary Resettlement.
The most significant use of land will be for excavation spoil deposit areas, for borrow material pits (located mostly within the rivers’ floodplains) and for construction camps (at Mirahuay and Pampa Libre), in this case a temporary use.
The Project’s above ground footprint is very limited and includes mainly the reservoir, dams and associated facilities at Huaura, Checras and Picunche. The transmission line’s alignment was designed to minimize potential impacts and its footprint is limited to transmission tower foundations and improvement and/or construction of new access roads that are expected to be minimal. The most significant use of land will be for excavation spoil deposit areas, for borrow material pits (located mostly within the rivers’ floodplains) and for construction camps (at Mirahuay and Pampa Libre), in this case, a temporary use. These ground interventions affect mostly unoccupied desert lands and river floodplain areas, with limited land use. Therefore, no physical resettlement, and only minor economic displacement, with be required.
The Company will acquire 90.5 hectares of land, some of which will be for temporary use, and will acquire a 25 meters-wide easement corridor over the extension of the transmission line (77 kms). Approximately 75% of the land is owned by Rural Andean Communities (Comunidades Campesinas or RACs) and the rest by the State and privately parties. Project-related land acquisition process commenced in June 2007 and by September 2010 that project had acquired 85% of land required for the project and transmission line. An Integrated Social Management Plan based on PS1, PS5 and PS7 has been prepared and includes procedures and principles to conduct consultations, valuation criteria, negotiation, compensation and grievance redress for the land and easement acquisition process. The Company is making efforts to acquire all land and easements through negotiated settlements thereby avoiding the need to pursue administrative means. Valuation of properties, improvements, and crops are based on full replacement cost assessed by professional valuators through land experts and agronomists. Further details regarding land negotiations with Rural Andean Communities (RACs) is described under PS7 below.
Economic displacement will be minimal and limited to the Mirahuay area, where a 2.5-hectares apple plantation owned by 5 individuals will be directly affected by the implementation of campsite and spoil areas. Even though these 2.5 hectares are a marginal portion of the total area owned by the affected people and impacts on their livelihoods are expected to be minimal, the Company will develop an Abbreviated Compensation Procedure to address these type of impacts and will include a detailed socio-economic baseline of the 5 affected individuals, identifying impacts and defining compensation and monitoring procedures to ensure and document the reestablishment of their livelihoods.
PS6: Biodiversity Conservation and Sustainable Natural Resource Management.
The project is located in a semi-arid area highly influenced by mining activities. Ecological baseline studies confirmed that the biodiversity of the area of influence is limited and mostly composed of non-native species, and that human activity has substantially modified the areas’ primary ecological function and species composition. No protected areas, sensitive ecological sites, highly diverse or fragile ecosystems, nor endemic species that require conservation efforts are present within the Cheves concession area or along the transmission line. Only two introduced fish species were identified in both seasons, namely rainbow trout (Oncorhynchus mykiss) and Pejerrey fish (Basilichthys semotilus). Local communities do not use the river for fishing and the species identified in the monitoring probably represent escapes from upstream fish farms.
This project is likely to contribute to the further degradation of the Huaura and Checras River modified ecosystem due to (a) the reduced flow rates (1 m3/s) in the 16 km reach of the Huaura river between the Checras reservoir and the tailrace tunnel outflow, (b) the physical barriers resulting from the construction of the 3 dams and the effect of flushing sediments, and (c) daily flow fluctuation during dry months from 1 m3/s to 33 m3/s resulting from peak operation. The latter impact will affect 9.6 km of the Huaura river reach between the powerhouse tailrace and the Picunche compensation dam, where this daily fluctuation in flow will effectively prevent the consolidation of an ecological steady-state.
The minimum flow on (a) previous experience with minimum flow releases of 2-3% of the average annual flow (@0.6-0.9 m3/s) in arid and semi-arid regions, (b) limited-to-no biodiversity value in the Huaura-Checras river ecosystem, and (c) minimum water uses in the reduce flow segment of the river (only two intakes of 20 l/s or 0.04 m3/s). Due to characteristics of the limited fish population / biodiversity value and to the fact that only two (2) water users that extract minimum quantities directly from the reduced flow segment have been identified, the 1.0 m3/sec flow is considered reasonable. Additionally, it must be noted that the minimum flow releases are expected to occur only during the 3-4 dry month periods (@30% of the year), and that in the 17 km segment with reduced flow there are two perennial tributaries, the Quebrada de Paccho and Quebrada de Huancoy.
The Company will design an Ecological Flow Management Plan, strengthening the existing hydro-biological baseline, proposing a robust a aquatic monitoring protocol to better understand the significance of the potential degradation caused by the reduced flows, and propose –via an adaptive management approach – potential mitigation, compensation and offset measures, if and as needed. This Plan will evaluate possible compensation and/or offsets measures to guarantee no net-loss, especially in light of the complete conversion of the 10-km segment from the tailrace to the compensation reservoir. Some of the initial proposed measures include (a) physical modification in of the river channel, (b) breeding and re-introduction of native fish species, (c) and/or the promotion of protection/conservations strategies in some of the healthier tributaries upstream.
PS7: Indigenous Peoples.
No significant impacts on Rural Andean Communities (Comunidades Campesinas or “RACs”) are expected from the construction or operation of the Project, however the Project will require land and easement acquisition of 67.5 hectares of arid and semi-arid land owned by 10 different RACs located in the project’s direct area of influence. Communal land ownership, collective attachment to ancestral lands, collective use of natural resources (e.g. pasture lands), and traditional work and decision-making institutions are common in RACs. Spanish is the language most broadly used in the area, while Quecua is spoken by few. Most RACs are poor, vulnerable, and dependent on small-scale farming, herding, and grazing and agricultural wage labor for their livelihoods. The Peruvian legal framework recognizes and protects the land rights and cultural particularities of the RACs. RACs have different levels of access to social services, roads, and markets. The identification of RAC members as indigenous peoples is a complex issue given the different levels of integration of these communities into the broader society and the fact that generally the members of these communities do not self-identify as indigenous. However, given the above described cultural and socioeconomic characteristics, the project will treat them in accordance with the requirements of IFC’s PS 7.
Accordingly, the Company has prepared an Integrated Social Management Plan (ISMP) aimed at minimizing and mitigating potential impacts on RACs and enhancing potential benefits in a culturally appropriated way in accordance with PS 7 objectives. The ISMP includes objectives and principles for: minimizing impacts and mitigating unavoidable impacts; continuous and on-going information sharing and consultation; free and easily accessible attention to grievances; preferential hiring of local people; and compensation at full replacement cost for the use of land and other resources (see PS5 above).
Agreements concerning the nature of the on-going consultation and land acquisition process were signed with each community following after a process of Good Faith Negotiation and in accordance with Peruvian legal requirements. These agreements also include commitments by the Company towards the RACs, including commitments on community development investments beyond land compensation. Individual members of the RACs (comuneros) hold individual rights of “possession” over community lands where they live, plant crops or develop other activities. Thus, where the Project footprint interferes with community land that is in use and/or where specific installations or assets are in place, land-take negotiations need to take place both at the community level (indemnified for “land”) and at the individual “possessor” level (indemnified for “assets”, if any). Community level negotiations were held with each community’s elected officials, that included the President and the Community Directive (Directiva Comunal). Disclosure of negotiation progress and results to other community members was conducted by each community’s elected authorities, according to their own established practices.
The process of community engagement described under the Community Engagement section below has been designed to be culturally appropriate and to enable an on-going process of free, prior, and informed consultation with participation by RAC representative bodies.
PS8: Cultural Heritage.
As required under local legislation, thorough archaeological investigations have been conducted as part of the environmental and social assessment process. These resulted in identification of nearly 100 sites containing archaeological remains, some of which will need to be rescued and the others (for instance, under Transmission Line conductors) that will need to be only signaled. All this work was conducted by qualified archaeologists with proper register at the Instituto Nacional de Cultura (INC) and was approved by the INC through issuance of the required CIRAs (Certificate of Inexistence of Archaeological Remains).
Also as required under local legislation, archaeological monitoring will be conducted during construction, and there is a legally established chance find procedure that will be followed. This procedure is aligned with IFC’s PS8. It is important to point out that, where possible, the Project has been adjusted in order to minimize the needs to rescue or disturb archaeological remains. This has been possible mainly with respect to the Transmission Line’s alignment that was adjusted at several locations in order to avoid archaeological sites identified during the assessment.
On October 2009, the INC issued a CIRA (No 589/2006) concluding that there were no archaeological sites in specific sections of the Project’s generation component (i.e. Huaura intake, Checras intake, Adit 1, Discharge tunnel). The study did, however, required for the company to undertake archaeological excavations (Proyecto de Evaluación Archaeologico) at the two specific sites (Paccho 1 & 2) and develop an archaeological monitoring program during construction. The generation component of the Project will require a total of 21 CIRAs confirming that there are no archaeological remains in its footprint. Out of the 21 CIRAs, 15 have been obtained between 2008 and September 2010 and 5 are still in process. It is anticipated that these remaining CIRA’s will be obtained by October 2010 and prior to commencement of construction on those sections.
On the November 2007, the INC through Resolution No 1521/INC authorized an archaeological evaluation (without excavations) of the 76.5 km transmission line route from Cheves to Huacho. On March 2008, through Resolution No 450/INC, the INC approved the archaeological findings report for the transmission line and required the company to carry out excavations at 18 sites. The Resolution also required the company to propose ways to reduce the Project footprint at sites directly affected, or to propose alternative transmission line routes. Through Resolution RD No 1805/INC, on November 2009, the INC approved the Archaeological Evaluation Study and granted authorizations for 6 sites that had been delimited and sign-posted (i.e. Paran 2, Pariacoto 1ª Sector B, Cochacalla 2, Cochacalla 3, Calambuco 3, Vizquira 4). On 22 June 2010, the INC granted the CIRA for the whole transmission line corridor (Report No 2010-252).
The INC requires the Company to conduct archaeological monitoring throughout the construction period of all Project facilities. Cheves’ archaeologist is developing the Archaeology Monitoring Plan for the Project for INC approval. It is anticipated that INC archaeologists will visit and monitor the project every 3 to 4 months during construction.
