PS1: Social and Environmental Assessment and Management System
PS2: Labor and Working Conditions
PS3: Pollution Prevention and Abatement
PS4: Community Health, Safety and Security
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

This is a Category B project because a limited number of specific environmental and social impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Potential impacts are those primarily associated with construction activities, are likely to be limited to the project site; are short term; and likely to have limited adverse impacts because of the remote location and sufficient distance from sensitive environmental areas.

PS1: Social and Environmental Assessment and Management System

Social and Environmental Assessment
AEDB in collaboration with UNDP/GEF Wind Energy Project carried out a Regional Environmental Assessment (REA) of Wind Farms in the Gharo Wind Corridor (June 2009). Based on REA an EIA framework for wind power projects has been developed. The REA included: (i) Environmental & Socio-Economic Baseline Report with a detailed analysis of the environmental baseline of the Gharo wind corridor including the protected areas and Indus Delta – a Ramsar Site, Indus/Green flyway for migratory birds; (ii) Cumulative Impact Assessment & Alternatives covering Gharo Coastal Wind Farm area (where the Project is located); and (iii) Environmental Management Plan, a framework environmental management plan to provide guidance to each specific wind farm project to be developed within the Gharo wind corridor.

TGL’s proposed wind farm is one of 5 wind farm prospects in Gharo. TGL, through a local environmental consultancy, completed an independent IEE report in October 2009 using a standard methodology prescribed by Pakistan Environmental Protection Act of 1997 and the relevant international environmental and social requirements including IFC’s Performance Standards and also utilized the REA’s guidelines for environmental assessment for developments of wind farms in the Gharo Wind Corridor. Selection of the site was a result of a thorough alternative site analysis including (i) availability of wind resources in Gharo wind corridor (ii) access to the site and relative vicinity of the proposed HESCO Grid station point, (iii) vicinity to human settlement (iv) location of protected areas or water courses in the Project’s area and (v) the community’s interest in exploring the use of renewable energy which included a consultation process with the local grass root stakeholders and with some institutional stakeholders in Karachi during July 2009. EPA of the Government of Sindh reviewed the IEE and consequently issued the environmental approval on October 2010. Various conditions were attached to the EPA approval including the following provisions: (i) the project activity will not be carried out within the buffer zone of any protected areas designated under Sindh Wildlife Protection Act, (ii) maintaining of safe distance between the wind farm and communities (iii) location of the campsite, (iv) monitoring of impacts on wildlife by the Project during the migratory seasons of birds, and others.

Subsequently, TGL prepared a Supplemental IEE Report in December 2011. The Report provided assurances that any potential negative impacts to biodiversity are only minimal and that it can be managed through appropriate EMP. In February 2012 TGL commissioned a field based study “Faunal Baseline Environmental Study” confirming that there are no Protected Areas in the vicinity of the TGL project site assuring that EPA requirements will be satisfied.

Management Program
As part of the IEE, and based on REA guidelines, an EMP was developed consisting of the organizational structure and roles and responsibilities, mitigation plan, monitoring plan, change management plan, communication and documentation and environmental training. The mitigation plan is a key component of the EMP. It lists all the potential effects of each activity of the project and their associated mitigation measures identified in the IEE. For each project activity, the following information is presented in the plan (i) a listing of the potential impact associated with that project activity, (ii) a comprehensive listing of mitigation measures (actions), (iii) the person(s) responsible for ensuring the full implementation of the action, (iv) the person(s) responsible for monitoring the action, (v) the timing of the implementation of the action to ensure that the objectives of mitigation are fully met. The mitigation measures will be translated into environmental and social development requirements and made part of the contracts for the construction activities. Major mitigation measures for identified potential impacts are summarized under relevant PS sections below. Important element of the EMP includes establishment of an ongoing independent avian and other fauna, flora and natural habitats monitoring plan. Mitigation measures to minimize avian collisions are summarized under PS6 below.

Following the implementation of these measures, as described in EMP, it is considered that there will be no significant impacts associated with the project and that any negative impact will be mitigated accordingly. The EMP will be revised from time to time and will continuously evolve over the course of the project design, construction, operation and decommissioning.

Cumulative impacts associated with the project have been assessed to be minor to moderate; moderate impact mainly being related to the negative impacts on one local bird species. In order to further minimize potential for negative impact and arrange for appropriate mitigation measures during the construction and operation the TGL will appoint an Independent Ornithological Expert (IOE) who will develop and implement detailed bird/bats monitoring program in consultation with the relevant governmental agency / NGO in Pakistan. Currently no other infrastructural developments, as being defined by “Regional Masterplan Development” study, are underway in the wider project area as confirmed by Secretary Environment and Alternative Energy, Government of Sindh. For any future extension TGL will ensure that cumulative impacts at this site are assessed and mitigated in a manner consistent with the IFC Performance Standards. T-line construction fall under the responsibility of NTDC and will be constructed flowing guidelines provided by EPA Sindh, i.e. IEE will have to include consideration to aspects such safety setback distances to communities, potable water wells and archeological sites among others. TGL will closely monitor NTDC’s process for managing possible EHS impacts of T-Line alignment design and construction work and appropriately coordinate and share E&S performance information.

Organizational Capacity and Monitoring
TGL will establish the Environment, Health and Safety Department (EHSD) and develop and implement the EHS and socioeconomic management system for the Company, defining roles and responsibilities of various departments and their respective staff. The EMP as well as environmental management requirements and specifications will be included in all contracts TGL executes.

Environmental and social trainings will help to ensure that the requirements of the IEE and EMP are clearly understood and followed by all project personnel throughout the project period. The environmental and social training program will be finalized before the commencement of the project, during the detailed design phase. The training will be provided to the TGL staff, the construction contractors, and other staff engaged for the project. Training will cover all staff levels, ranging from the management and supervisory to the skilled and unskilled personnel. The scope of the trainings will cover general environmental awareness and the requirements of the IEE and the EMP, with special emphasis on sensitizing the project staff to the environmental and social aspects of the area. During the O&M phase of the project, these trainings will continue to be conducted by EHSD for all relevant staff of the Company.

TGL’s EHS manager or other EHS TGL field staff or the Supervision Consultant (if TGL chooses to employ one) through its Resident Engineer (RE) will be responsible for managing all construction related EHS impacts and ensuring that the CMEC, GE and other contractor(s) adhere to the quality requirements and other commitments including implementation of the EMP and IEE. The contractors’ Chief Executive Officers or Country Managers will assume the main responsibility for all EHS and social matters pertaining to their works while the field management and quality control during the construction phase will be the responsibility of theirs site managers. During the operation phase of the project, management of EHS and social development aspects will become a routine function, as an integral part of GE’s O&M activities. The TGL EHS manager will be the focal point for all matters relating to EHS and socioeconomic aspects during the routine operations of the power plant.

If any monitoring teams from government departments (e.g. Sindh EPA) or from NGOs visit the field during the field activities, the EHS Department will be responsible for coordinating their visits.


PS2: Labor and Working Conditions

During the construction phase of the project it is expected that people from surrounding communities will be hired for unskilled jobs. On an average, around 200 direct workers will be required during the construction phase. This will increase to around 600 for five months of the construction period, with a peak of 800 staff. Additionally, around 110 support staff will also be hired. For the operational phase the project will employ maximum of 5 people and these will not reside at the site; it is planned that they will be employed on three shifts, in addition to the security staff.

TGL will establish a written HR Policy and will provide access of this to all staff, both employee and non-employee workers. The TGL’s HR policy and procedures will be in line with IFC Performance Standard 2 (Labor and Working Conditions) i.e. to address workers’ rights related to contracts and terms of employment, working hours and overtime, training, leaves, grievance redress, retirement, employee welfare, disciplinary action, health and safety, and benefits wages and benefits, the principle of equal opportunity, fair treatment and non-discrimination and grievance mechanism. This is included in the Environmental and Social Action Plan (ESAP) agreed by IFC. All contracts with contractors and subcontractors will include a clause requiring compliance with the ESAP, EMP and PS2.

Besides its own workforce the international contractor(s) may need to subcontract additional workforce locally, hiring of which will be in accordance with relevant Pakistani labor law. Contractor(s) will be responsible that all sub-contractors receive an EHS induction prior to starting work, a work-site orientation and on-the-job or formal training prior to being assigned a job. No expatriate workers are expected to be on site. Although the use of child labor is not prevalent in the construction works such as those involved in the proposed project, the provisions of the Child Labor Act will still be made part of the construction contracts, in order to ensure that no child labor is employed at the project sites or campsites.

During construction, a temporary camp to house workers is to be built following the national local standards, and the best practice including the guidelines for worker’s accommodation prepared by IFC and EBRD; these include provision of safe housing, availability of electricity, plumbing, water and sanitation, adequate fire protection and dormitory/room facilities e.g. (i) usual standards range from 10 to 12.5 cubic meters (volume) or 4 to 5.5 square meters (surface), (ii) a minimum ceiling height of 2.10 meters, (iii) in collective rooms only a reasonable number of workers are allowed to share the same room - standards range from 2 to 8 workers, etc. The site will likely cover an area of 12,000 m2 and will have 4 construction trailers and 4 equipment storage trailers. There will also be vehicle parking and equipment staging areas. The camp will require 8000 liters of water each day. Potable water from the Leete Village will be used for the camps without impacting potable water availability for the village itself. This water will be stored in a plastic tank. The drainage and sewerage system will be constructed i.e. soak pits for the collection of wastewater from kitchen and washing / ablution areas and septic tanks for sewage from the toilets. Sewage and solid waste disposal trucks will be used to remove the sludge, sewage and solid waste from the site. Storm water drainage will be managed by controlled flow into the tidal creeks.

Occupational Health and Safety
The EMP Plan is designed to manage the health and safety and environmental performance; responsibility for implementation of EMP will be with TGL. Integral parts of this Plan are (i) the General Construction Contractor (CMEC) and (ii) O&M Contractor (GE) HSE Plans. These HSE Plans include management systems, health, safety and environmental programs, roles and the responsibility and site procedures, among others provisions.

GE applies best practice international standards 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.
CMEC is internationally experienced company that operates to international best practice standards in construction and operations. As the project management contractor it has to ensure that each sub-contractor submits, at the tender stage, proof of its good OHS practices in order to be shortlisted for the work. In case that sub-contractors are required to execute specific specialist works on site (e.g., demolition, excavation, electrical work, welding) they will be required to describe a work method i.e. specifying how to reduce or eliminate potential risks. Safety induction meetings will be regularly conducted, and incident statistics maintained. A site management plan, safety & health plan, including emergency response and hazardous material/waste management plans are obligatory under National OHS law. Health and safety staff will be appointed and present on the construction site during working hours and will include an on-site first aid emergency capacity.

During the construction phase the primary responsibilities for managing EHS impacts lay with TGL while field management and quality control will be the responsibility of CMEC and the other contractor(s) site managers who will also be responsible for communication with and the training of their respective construction and camp crews in all aspects of the EMP.
During the operation phase of the project, management of EHS and social development aspects will become a routine function, as an integral part of GE’s O&M activities. The TGL EHS manager will be the focal point for all matters relating to EHS and socioeconomic aspects during the routine operations of the power plant.


PS3: Pollution Prevention and Abatement

Construction Phase
Environmental impacts during the construction works will be temporary in nature. TGL, through its main contractor CMEC, will ensure that the project is developed according to IFC EHS Guidelines and good industry practices. Work will commence with construction of the connecting road to the site from the Coastal Highway. Road construction and expansion during construction will require proper drainage and erosion management, for this specific contractor actions and responsibilities are established in the EMP. The roads within the project area will be around 12 km long, and will also have a compacted gravel and clay surface and will be constructed 800 to 1000 mm higher than natural ground. This will allow the water to flow over these roads during the high tide and so there will be no obstruction to the natural flow of water. Culverts will be provided at suitable locations. Each turbine location will involve compaction of around 36m x 12m area, raising to a level 0.5m higher than the maximum tide level and covering with a compacted gravel and clay surface.

As part of the contractor’s construction management plan a hazardous materials management procedure will be established for appropriate selection, purchasing, storage and handling of fuels and chemicals which will be used on the site. There will be no on-site maintenance of vehicles so to avoid accidental soil pollution. Fuel storage will be fully contained and spill response equipment will be present on site. The Contractor will prepare a fuel management plan and a spill control, prevention, and countermeasure plan as a specific component of their Emergency Preparedness and Response Plan. A limited quantities of general household waste will be generated during construction and maintenance (packaging, metals, plastics, filters, oils etc.), which will be disposed of in designated places by licensed contractors and/or recycled where possible.

Minor sources of air emissions during construction will be generated by vehicles, construction machinery, and small welding and power generators. Low sulfur content will be part of supply criteria for the diesel fuel used by this equipment. The daily fuel requirement will be approximately 6500 liters. Emissions from the vehicle engines and generators will be minimized by ensuring that the engines are always properly tuned and maintained.

Operational Phase
O&M activities will not be very extensive. This will include mainly regular periodic maintenance activities. Fuels and oils will be stored in containers in areas with impervious floors and surrounded by containment bunds. Recyclable materials will periodically be transported out of the site and sold / given to contractors. Non-recyclable material will be collected and disposed of at designated landfill sites. The drainage and sewerage system constructed during the construction phase will continue to be used during the operations phase of the project. Sewage and solid waste disposal trucks will be used to remove the sludge, sewage and solid waste from the site. Storm water drainage will be managed by controlled flow into the tidal creeks.

The Project is expected to generate 127.4 GWh per annum at 29.4% plant factor resulting in annual GHG emission displacement of approx 55,000 ton CO2 per year, based on the Pakistan’s grid average GHG emissions performance per unit of electricity generation of 0.432 tonCO2/MWh (2006-2008 average, 2010 International Energy Agency statistics). The Company is reviewing a feasibility of having the Project registered under United Nations Framework Convention on Climate Change (UNFCCC) Clean Development Mechanism (CDM).

PS4: Community Health, Safety and Security

Construction related impacts for the communities are likely to be limited due to the remoteness of the project location. The vehicular traffic on the local roads can potentially pose low level of adverse impact as it will involve moving of heavy machinery, loaders, bulldozers and trucks and transport of raw materials and construction waste and construction of new roads that will enable access to each individual turbine. Potential negative impact will be mitigated by introducing a strict code of conduct for the construction workers and drivers, including posting road signage at appropriate locations to reduce safety hazard associated with project-related vehicular traffic and promoting defensive driving in section where road passes near / within the communities. The main contractor will develop a traffic management plan to ensure that the movements through any settlements are phased out and limited to the day light hours. TGL will inform all local communities about this plan and make the plan available locally. If necessary, the movement of construction vehicles will be routed to avoid, residential areas where possible, thereby minimizing potential noise and dust impacts. During the operation of the wind farm it is anticipated that vehicular access to the wind farm will be minimal and related only to periodic maintenance.

Due to the fact that the local population residing in the vicinity of the Project area are far away from the Project site no impacts or risks to the health and safety of the general public are expected from the malfunction of the wind turbines including the risk of potential blade throw; shadow flicker/blade glint impact will be negligible too. At greater distances, the impact of the turbines on visual amenity at the landscape level reduces to negligible or no effect.
The wind turbines will operate continuously at wind speeds between 3 m/s and max 20 m/s. At speeds greater than 20 m/s the turbines automatically shut off for safety reasons. The turbines will be equipped with the latest safety alarm and connected to a network of safety instruments and communication devices that can be used for remote monitoring. The company will consider, if required, installing protective fencing around individual turbines, which will also be securely locked to prevent any unauthorized entry. The Company will also use safety warning signage to inform the community of the potential risk of attempting to access wind towers. Before commencing the testing commissioning of the system, the nearby communities will be informed. Protective fencing will be used where appropriate.

During the construction phase site the Contractors will be responsible for access control and security procedures on the site. If needed a security services will be subcontracted and managed by an established security service provider that has formal procedures and codes of conduct. This is not deemed to be a significant risk to communities in the area. After the project is completed TGL will employ only necessary authorized armed personnel that will not be resident on site. Their task will be to periodically oversee the operations of the plant, conditions along the connection T-lines, around transformer station, and turbines.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The project site is located in an inter-tidal coastal area with sparse growth of mangroves and on the northwest periphery of the Gharo wind corridor. The area leading to the site from the Jam Sakro Canal road is populated with cultivation fields and orchards. Therefore, the natural fauna in this area has long left this area, and the species that exist today are those which have adapted to the human presence and modified habitat. The project site and its immediate vicinity do not support natural vegetation of any ecological significance. The site does not provide habitat to any terrestrial or avian faunal species, nor is it located along the main route of migratory birds. Most of the area is barren, with scanty vegetation and the avifauna has already moved into the grassy beds at the corner of the creek away from the project area suggesting that (i) the feeding area of the water birds lies along the marshes of the creek area which is not included in the project area and will not be affected due to the project and (ii) the dislocation of wildlife of the project area seems to have already taken place during the early phase of the construction of the Coastal Highway and that the water birds, which form a major part of the wildlife of the area, have already settled by finding refuge in the marshes amongst the grassy patches in the creek area. Compared to the overall size of the entire Indus Delta (about 600,000 hectares), the proposed site is a very small tract of land – about 0.09%, hence the loss of the site as the feeding ground for the wild birds is unlikely to be significant.

The mangroves along Sindh coast are one of the most important ecosystems of coastal zone of Sindh and unusual in that they occur in an arid climate. The mangrove ecosystem stretches along the entire Sindh coast from east of Karachi to Sir Creek covering the whole of Indus River Delta past and present. The present Indus Delta is spread over an area of 600,000 hectares (ha), of which as much as 260,000 ha are covered with mangrove vegetation which has been estimated through satellite imageries. The mangroves of the Sindh Coastal areas at present do not receive fresh water continuously which is required for their healthy growth. Mangroves in the vicinity of Karachi receive their fresh water supply from domestic and industrial effluents through Lyari and Malir Rivers, while the mangroves in the delta depend on the fresh water supply from River Indus. By observing the growth of mangroves it may be presumed that in the past this area might have been a healthy growing mangrove forest but due to scarcity of fresh water the salinity has increased in the area and affected the growth of the mangroves.

Although the existing studies suggest that the impact on birdlife in the area will be limited, TGL’s EMP will have a set of mitigation measures to reduce the impacts of the power plant operation on birds mortality including (i) appropriate storm water management measures will be implemented to avoid creating attractions such as small ponds which can attract birds for feeding or nesting near the wind farm (ii) the towers and turbines will be made visible by using appropriate colors (iii) the towers will have light beacons to make them visible for the nighttime flying birds, (iv) erecting wind towers minimum at a distance of 300 m to avoid the avian collision of 3-5 rotor diameters across the prevailing wind energy direction (minimum 200m) to avoid the avian collision, (v) placement of power and communication cables underground to reduce the chance of any avian collision, (vi) conducting bird mortality count and (vii) working closely with the local partners involved in the conservation efforts. Working with local and international flora and fauna conservation partners (IUCN, WWF Pakistan) the Company plans to ensure that proper monitoring programs are in place and appropriate follow-up mitigation will be implemented. The Environmental and Social Action Plan agreed with the Company specifies the action to operate the Project to ensure no significant impact on the viability of the population of any given species of birds. TGL will retain an Independent Ornithological Expert (IOE) to establish a monitoring program that would contain an agreed protocol for mitigation measures, including the reduction of the speed of the turbines or, potentially, for the turbines to be temporarily turned off should a migrant flock be observed to be approaching either site. The habitat alteration will be limited to the footprint of the towers and buildings, and the site roads. The expert advice will be obtained for any plantation carried out at the site. No exotic plant species will be introduced; only indigenous species will be planted. Habitat improvement measures, such as planting mangroves at the outer boundary (facing the creek channels), will be taken, after obtaining expert advice.

Social and Environmental Assessment

AEDB in collaboration with UNDP/GEF Wind Energy Project carried out a Regional Environmental Assessment (REA) of Wind Farms in the Gharo Wind Corridor (June 2009). Based on REA an EIA framework for wind power projects has been developed. The REA included: (i) Environmental & Socio-Economic Baseline Report with a detailed analysis of the environmental baseline of the Gharo wind corridor including the protected areas and Indus Delta – a Ramsar Site, Indus/Green flyway for migratory birds; (ii) Cumulative Impact Assessment & Alternatives covering Gharo Coastal Wind Farm area (where the Project is located); and (iii) Environmental Management Plan, a framework environmental management plan to provide guidance to each specific wind farm project to be developed within the Gharo wind corridor.



TGL’s proposed wind farm is one of 5 wind farm prospects in Gharo. TGL, through a local environmental consultancy, completed an independent IEE report in October 2009 using a standard methodology prescribed by Pakistan Environmental Protection Act of 1997 and the relevant international environmental and social requirements including IFC’s Performance Standards and also utilized the REA’s guidelines for environmental assessment for developments of wind farms in the Gharo Wind Corridor. Selection of the site was a result of a thorough alternative site analysis including (i) availability of wind resources in Gharo wind corridor (ii) access to the site and relative vicinity of the proposed HESCO Grid station point, (iii) vicinity to human settlement (iv) location of protected areas or water courses in the Project’s area and (v) the community’s interest in exploring the use of renewable energy which included a consultation process with the local grass root stakeholders and with some institutional stakeholders in Karachi during July 2009. EPA of the Government of Sindh reviewed the IEE and consequently issued the environmental approval on October 2010. Various conditions were attached to the EPA approval including the following provisions: (i) the project activity will not be carried out within the buffer zone of any protected areas designated under Sindh Wildlife Protection Act, (ii) maintaining of safe distance between the wind farm and communities (iii) location of the campsite, (iv) monitoring of impacts on wildlife by the Project during the migratory seasons of birds, and others.



Subsequently, TGL prepared a Supplemental IEE Report in December 2011. The Report provided assurances that any potential negative impacts to biodiversity are only minimal and that it can be managed through appropriate EMP. In February 2012 TGL commissioned a field based study “Faunal Baseline Environmental Study” confirming that there are no Protected Areas in the vicinity of the TGL project site assuring that EPA requirements will be satisfied.



Management Program

As part of the IEE, and based on REA guidelines, an EMP was developed consisti
ng of the organizational structure and roles and responsibilities, mitigation plan, monitoring plan, change management plan, communication and documentation and environmental training. The mitigation plan is a key component of the EMP. It lists all the potential effects of each activity of the project and their associated mitigation measures identified in the IEE. For each project activity, the following information is presented in the plan (i) a listing of the potential impact associated with that project activity, (ii) a comprehensive listing of mitigation measures (actions), (iii) the person(s) responsible for ensuring the full implementation of the action, (iv) the person(s) responsible for monitoring the action, (v) the timing of the implementation of the action to ensure that the objectives of mitigation are fully met. The mitigation measures will be translated into environmental and social development requirements and made part of the contracts for the construction activities. Major mitigation measures for identified potential impacts are summarized under relevant PS sections below. Important element of the EMP includes establishment of an ongoing independent avian and other fauna, flora and natural habitats monitoring plan. Mitigation measures to minimize avian collisions are summarized under PS6 below.



Following the implementation of these measures, as described in EMP, it is considered that there will be no significant impacts associated with the project and that any negative impact will be mitigated accordingly. The EMP will be revised from time to time and will continuously evolve over the course of the project design, construction, operation and decommissioning.



Cumulative impacts associated with the project have been assessed to be minor to moderate; moderate impact mainly being related to the negative impacts on one local bird species. In order to further minimize potential for negative impact and arrange for appropriate mitigation measures during the construction and operation the TGL will appoint an Independent Ornithological Expert (IOE) who will develop and implement detailed bird/bats monitoring program in consultation with the relevant governmental agency / NGO in Pakistan. Currently no other infrastructural developments, as being defined by “Regional Masterplan Development” study, are underway in the wider project area as confirmed by Secretary Environment and Alternative Energy, Government of Sindh. For any future extension TGL will ensure that cumulative impacts at this site are assessed and mitigated in a manner consistent with the IFC Performance Standards. T-line construction fall under the responsibility of NTDC and will be constructed flowing guidelines provided by EPA Sindh, i.e. IEE will have to include consideration to aspects such safety setback distances to communities, potable water wells and archeological sites among others. TGL will closely monitor NTDC’s process for managing possible EHS impacts of T-Li
ne alignment design and construction work and appropriately coordinate and share E&S performance information.



Organizational Capacity and MonitoringTGL will establish the Environment, Health and Safety Department (EHSD) and develop and implement the EHS and socioeconomic management system for the Company, defining roles and responsibilities of various departments and their respective staff. The EMP as well as environmental management requirements and specifications will be included in all contracts TGL executes.

Environmental and social trainings will help to ensure that the requirements of the IEE and EMP are clearly understood and followed by all project personnel throughout the project period. The environmental and social training program will be finalized before the commencement of the project, during the detailed design phase. The training will be provided to the TGL staff, the construction contractors, and other staff engaged for the project. Training will cover all staff levels, ranging from the management and supervisory to the skilled and unskilled personnel. The scope of the trainings will cover general environmental awareness and the requirements of the IEE and the EMP, with special emphasis on sensitizing the project staff to the environmental and social aspects of the area. During the O&M phase of the project, these trainings will continue to be conducted by EHSD for all relevant staff of the Company.



TGL’s EHS manager or other EHS TGL field staff or the Supervision Consultant (if TGL chooses to employ one) through its Resident Engineer (RE) will be responsible for managing all construction related EHS impacts and ensuring that the CMEC, GE and other contractor(s) adhere to the quality requirements and other commitments including implementation of the EMP and IEE. The contractors’ Chief Executive Officers or Country Managers will assume the main responsibility for all EHS and social matters pertaining to their works while the field management and quality control during the construction phase will be the responsibility of theirs site managers. During the operation phase of the project, management of EHS and social development aspects will become a routine function, as an integral part of GE’s O&M activities. The TGL EHS manager will be the focal point for all matters relating to EHS and socioeconomic aspects during the routine operations of the power plant.



If any monitoring teams from government departments (e.g. Sindh EPA) or from NGOs visit the field during the field activities, the EHS Department will be responsible for coordinating their visits.

During the construction phase of the project it is expected that people from surrounding communities will be hired for unskilled jobs. On an average, around 200 direct workers will be required during the construction phase. This will increase to around 600 for five months of the construction period, with a peak of 800 staff. Additionally, around 110 support staff will also be hired. For the operational phase the project will employ maximum of 5 people and these will not reside at the site; it is planned that they will be employed on three shifts, in addition to the security staff.



TGL will establish a written HR Policy and will provide access of this to all staff, both employee and non-employee workers. The TGL’s HR policy and procedures will be in line with IFC Performance Standard 2 (Labor and Working Conditions) i.e. to address workers’ rights related to contracts and terms of employment, working hours and overtime, training, leaves, grievance redress, retirement, employee welfare, disciplinary action, health and safety, and benefits wages and benefits, the principle of equal opportunity, fair treatment and non-discrimination and grievance mechanism. This is included in the Environmental and Social Action Plan (ESAP) agreed by IFC. All contracts with contractors and subcontractors will include a clause requiring compliance with the ESAP, EMP and PS2.



Besides its own workforce the international contractor(s) may need to subcontract additional workforce locally, hiring of which will be in accordance with relevant Pakistani labor law. Contractor(s) will be responsible that all sub-contractors receive an EHS induction prior to starting work, a work-site orientation and on-the-job or formal training prior to being assigned a job. No expatriate workers are expected to be on site. Although the use of child labor is not prevalent in the construction works such as those involved in the proposed project, the provisions of the Child Labor Act will still be made part of the construction contracts, in order to ensure that no child labor is employed at the project sites or campsites.



During construction, a temporary camp to house workers is to be built following the national local standards, and the best practice including the guidelines for worker’s accommodation prepared by IFC and EBRD; these include provision of safe housing, availability of electricity, plumbing, water and sanitation, adequate fire protection and dormitory/room facilities e.g. (i) usual standards range from 10 to 12.5 cubic meters (volume) or 4 to 5.5 square meters (surface), (ii) a minimum ceiling height of 2.10 meters, (iii) in collective rooms only a reasonable number of workers are allowed to share the same room - standards range from 2 to 8 workers, etc. The site will likely cover an area of 12,000 m2 and will have 4 construction trailers and 4 equipment storage trailers. There will also be vehicle parking and equipment staging areas. The camp will require 8000 liters of
water each day. Potable water from the Leete Village will be used for the camps without impacting potable water availability for the village itself. This water will be stored in a plastic tank. The drainage and sewerage system will be constructed i.e. soak pits for the collection of wastewater from kitchen and washing / ablution areas and septic tanks for sewage from the toilets. Sewage and solid waste disposal trucks will be used to remove the sludge, sewage and solid waste from the site. Storm water drainage will be managed by controlled flow into the tidal creeks.



Occupational Health and Safety

The EMP Plan is designed to manage the health and safety and environmental performance; responsibility for implementation of EMP will be with TGL. Integral parts of this Plan are (i) the General Construction Contractor (CMEC) and (ii) O&M Contractor (GE) HSE Plans. These HSE Plans include management systems, health, safety and environmental programs, roles and the responsibility and site procedures, among others provisions.



GE applies best practice international standards 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.

CMEC is internationally experienced company that operates to international best practice standards in construction and operations. As the project management contractor it has to ensure that each sub-contractor submits, at the tender stage, proof of its good OHS practices in order to be shortlisted for the work. In case that sub-contractors are required to execute specific specialist works on site (e.g., demolition, excavation, electrical work, welding) they will be required to describe a work method i.e. specifying how to reduce or eliminate potential risks. Safety induction meetings will be regularly conducted, and incident statistics maintained. A site management plan, safety & health plan, including emergency response and hazardous material/waste management plans are obligatory under National OHS law. Health and safety staff will be appointed and present on the construction site during working hours and will include an on-site first aid emergency capacity.



During the construction phase the primary responsibilities for managing EHS impacts lay with TGL while field management and quality control will be the responsibility of CMEC and the other contractor(s) site managers who will also be responsible for communication with and the training of their respective construction and camp crews in all aspects of the EMP.

During the operation phase of the project, management of EHS and social development aspects will become a routine function, as an integral part of GE’s O&M activities. The TGL EHS manager will be the focal point for all matters relating to EHS and socioeconomic aspects
during the routine operations of the power plant.

Construction Phase

Environmental impacts during the construction works will be temporary in nature. TGL, through its main contractor CMEC, will ensure that the project is developed according to IFC EHS Guidelines and good industry practices. Work will commence with construction of the connecting road to the site from the Coastal Highway. Road construction and expansion during construction will require proper drainage and erosion management, for this specific contractor actions and responsibilities are established in the EMP. The roads within the project area will be around 12 km long, and will also have a compacted gravel and clay surface and will be constructed 800 to 1000 mm higher than natural ground. This will allow the water to flow over these roads during the high tide and so there will be no obstruction to the natural flow of water. Culverts will be provided at suitable locations. Each turbine location will involve compaction of around 36m x 12m area, raising to a level 0.5m higher than the maximum tide level and covering with a compacted gravel and clay surface.



As part of the contractor’s construction management plan a hazardous materials management procedure will be established for appropriate selection, purchasing, storage and handling of fuels and chemicals which will be used on the site. There will be no on-site maintenance of vehicles so to avoid accidental soil pollution. Fuel storage will be fully contained and spill response equipment will be present on site. The Contractor will prepare a fuel management plan and a spill control, prevention, and countermeasure plan as a specific component of their Emergency Preparedness and Response Plan. A limited quantities of general household waste will be generated during construction and maintenance (packaging, metals, plastics, filters, oils etc.), which will be disposed of in designated places by licensed contractors and/or recycled where possible.



Minor sources of air emissions during construction will be generated by vehicles, construction machinery, and small welding and power generators. Low sulfur content will be part of supply criteria for the diesel fuel used by this equipment. The daily fuel requirement will be approximately 6500 liters. Emissions from the vehicle engines and generators will be minimized by ensuring that the engines are always properly tuned and maintained.



Operational Phase

O&M activities will not be very extensive. This will include mainly regular periodic maintenance activities. Fuels and oils will be stored in containers in areas with impervious floors and surrounded by containment bunds. Recyclable materials will periodically be transported out of the site and sold / given to contractors. Non-recyclable material will be collected and disposed of at designated landfill sites. The drainage and sewerage system constructed during the construction phase will continue to be used during the operations phase of the project. Sewage and solid waste dispo
sal trucks will be used to remove the sludge, sewage and solid waste from the site. Storm water drainage will be managed by controlled flow into the tidal creeks.



The Project is expected to generate 127.4 GWh per annum at 29.4% plant factor resulting in annual GHG emission displacement of approx 55,000 ton CO2 per year, based on the Pakistan’s grid average GHG emissions performance per unit of electricity generation of 0.432 tonCO2/MWh (2006-2008 average, 2010 International Energy Agency statistics). The Company is reviewing a feasibility of having the Project registered under United Nations Framework Convention on Climate Change (UNFCCC) Clean Development Mechanism (CDM).

Construction related impacts for the communities are likely to be limited due to the remoteness of the project location. The vehicular traffic on the local roads can potentially pose low level of adverse impact as it will involve moving of heavy machinery, loaders, bulldozers and trucks and transport of raw materials and construction waste and construction of new roads that will enable access to each individual turbine. Potential negative impact will be mitigated by introducing a strict code of conduct for the construction workers and drivers, including posting road signage at appropriate locations to reduce safety hazard associated with project-related vehicular traffic and promoting defensive driving in section where road passes near / within the communities. The main contractor will develop a traffic management plan to ensure that the movements through any settlements are phased out and limited to the day light hours. TGL will inform all local communities about this plan and make the plan available locally. If necessary, the movement of construction vehicles will be routed to avoid, residential areas where possible, thereby minimizing potential noise and dust impacts. During the operation of the wind farm it is anticipated that vehicular access to the wind farm will be minimal and related only to periodic maintenance.



Due to the fact that the local population residing in the vicinity of the Project area are far away from the Project site no impacts or risks to the health and safety of the general public are expected from the malfunction of the wind turbines including the risk of potential blade throw; shadow flicker/blade glint impact will be negligible too. At greater distances, the impact of the turbines on visual amenity at the landscape level reduces to negligible or no effect.

The wind turbines will operate continuously at wind speeds between 3 m/s and max 20 m/s. At speeds greater than 20 m/s the turbines automatically shut off for safety reasons. The turbines will be equipped with the latest safety alarm and connected to a network of safety instruments and communication devices that can be used for remote monitoring. The company will consider, if required, installing protective fencing around individual turbines, which will also be securely locked to prevent any unauthorized entry. The Company will also use safety warning signage to inform the community of the potential risk of attempting to access wind towers. Before commencing the testing commissioning of the system, the nearby communities will be informed. Protective fencing will be used where appropriate.



During the construction phase site the Contractors will be responsible for access control and security procedures on the site. If needed a security services will be subcontracted and managed by an established security service provider that has formal procedures and codes of conduct. This is not deemed to be a significant risk to communities in the area. After the project
is completed TGL will employ only necessary authorized armed personnel that will not be resident on site. Their task will be to periodically oversee the operations of the plant, conditions along the connection T-lines, around transformer station, and turbines.

The project site is located in an inter-tidal coastal area with sparse growth of mangroves and on the northwest periphery of the Gharo wind corridor. The area leading to the site from the Jam Sakro Canal road is populated with cultivation fields and orchards. Therefore, the natural fauna in this area has long left this area, and the species that exist today are those which have adapted to the human presence and modified habitat. The project site and its immediate vicinity do not support natural vegetation of any ecological significance. The site does not provide habitat to any terrestrial or avian faunal species, nor is it located along the main route of migratory birds. Most of the area is barren, with scanty vegetation and the avifauna has already moved into the grassy beds at the corner of the creek away from the project area suggesting that (i) the feeding area of the water birds lies along the marshes of the creek area which is not included in the project area and will not be affected due to the project and (ii) the dislocation of wildlife of the project area seems to have already taken place during the early phase of the construction of the Coastal Highway and that the water birds, which form a major part of the wildlife of the area, have already settled by finding refuge in the marshes amongst the grassy patches in the creek area. Compared to the overall size of the entire Indus Delta (about 600,000 hectares), the proposed site is a very small tract of land – about 0.09%, hence the loss of the site as the feeding ground for the wild birds is unlikely to be significant.



The mangroves along Sindh coast are one of the most important ecosystems of coastal zone of Sindh and unusual in that they occur in an arid climate. The mangrove ecosystem stretches along the entire Sindh coast from east of Karachi to Sir Creek covering the whole of Indus River Delta past and present. The present Indus Delta is spread over an area of 600,000 hectares (ha), of which as much as 260,000 ha are covered with mangrove vegetation which has been estimated through satellite imageries. The mangroves of the Sindh Coastal areas at present do not receive fresh water continuously which is required for their healthy growth. Mangroves in the vicinity of Karachi receive their fresh water supply from domestic and industrial effluents through Lyari and Malir Rivers, while the mangroves in the delta depend on the fresh water supply from River Indus. By observing the growth of mangroves it may be presumed that in the past this area might have been a healthy growing mangrove forest but due to scarcity of fresh water the salinity has increased in the area and affected the growth of the mangroves.



Although the existing studies suggest that the impact on birdlife in the area will be limited, TGL’s EMP will have a set of mitigation measures to reduce the impacts of the power plant operation on birds mortality including (i) appropriate storm water management measures will be im
plemented to avoid creating attractions such as small ponds which can attract birds for feeding or nesting near the wind farm (ii) the towers and turbines will be made visible by using appropriate colors (iii) the towers will have light beacons to make them visible for the nighttime flying birds, (iv) erecting wind towers minimum at a distance of 300 m to avoid the avian collision of 3-5 rotor diameters across the prevailing wind energy direction (minimum 200m) to avoid the avian collision, (v) placement of power and communication cables underground to reduce the chance of any avian collision, (vi) conducting bird mortality count and (vii) working closely with the local partners involved in the conservation efforts. Working with local and international flora and fauna conservation partners (IUCN, WWF Pakistan) the Company plans to ensure that proper monitoring programs are in place and appropriate follow-up mitigation will be implemented. The Environmental and Social Action Plan agreed with the Company specifies the action to operate the Project to ensure no significant impact on the viability of the population of any given species of birds. TGL will retain an Independent Ornithological Expert (IOE) to establish a monitoring program that would contain an agreed protocol for mitigation measures, including the reduction of the speed of the turbines or, potentially, for the turbines to be temporarily turned off should a migrant flock be observed to be approaching either site. The habitat alteration will be limited to the footprint of the towers and buildings, and the site roads. The expert advice will be obtained for any plantation carried out at the site. No exotic plant species will be introduced; only indigenous species will be planted. Habitat improvement measures, such as planting mangroves at the outer boundary (facing the creek channels), will be taken, after obtaining expert advice.

During July 2009 a public consultation with a number of grass root stakeholders in Haji Girano Union Council were held in order to apprise them of the project activities and to obtain their views and concerns. The consultations were held in several villages, located between 5 to 15 kilometers east to the project site, including meetings with approx 10 individuals. Efforts were made to solicit the concerns and views of rural women as well. Some of the villagers already knew about the project, but did not know the specific details. The participants generally welcomed the plans to establish the proposed power plant in the area as they are expecting improvements in the infrastructure, better el. power and water supply. Also they expect that the project would bring employment and small business/trade opportunities for the local population and overall improvement in quality of life. At IFC’s request the sponsor has undertaken an additional round of consultation with relevant institutional and non-governmental stakeholders in Pakistan, which were not initially consulted about the project, including IUCN, WWF, SWD, and Sindh Forestry Department.
The TGL will maintain the Social Complaint Register (SCR) at the sites to document all complaints received from the local communities or any other stakeholder. The information recorded in the Register will include date of the complaint, particulars of the complainant, description of the grievance, actions to be taken, the person responsible to take the action, follow up requirements and the target date for the implementation of the mitigation measure and the actual measures taken to mitigate these concerns.
TGL will disclose this IEE, EMP, Supplemental IEE Report and Faunal Baseline Environmental Study to all the stakeholders before the commencement of the proposed project. The IEE report will be made available to the stakeholders at the sites designated by the EPA, in accordance with the national legislation (PEPA 1997). In addition, the executive summary of the IEE, Supplemental IEE and Faunal Baseline Environmental Study will be translated into Urdu language (and Sindhi language if necessary), and made available to the affected communities (and also kept at the project sites). This will ensure that the local communities are aware of the project, its key impacts, the mitigation measures and the implementation mechanism. In addition, the Executive Summaries will be disclosed through the TGL’s official website.

The following documents are disclosed as attachment to this ESRS:- Initial Environmental Examination (IEE) 49.5 MW Wind Power Project – Gharo, Sindh, dated October 2009, prepared by environmental consultancy firm “Tekcellent” for Tenaga Generasi Limited (TGL).
- Supplemental Report to IEE, prepared by environmental consultancy firm “Tekcellent” for Tenaga Generasi Limited (TGL) in December 2011. This includes Environmental Management Plan and HSE Plans.
- Faunal Baseline Environmental Study, prepared in February 2012 by Tekcellent and SWD- Environmental and Social Action Plan, March 30, 2012- Regional Environmental Assessment Study of the Gharo Wind Corridor in Pakistan, prepared with assistance by the United Nations Development Programme (UNDP) of Pakistan, June 2009

The Company will locally disclose the above listed documents at the Company’s offices in Karachi and Thatta District. Any queries and/or comments about the Project may be directed to:

Mr. Hafeez Ur Rahman, Project Manager
Dawood Centre, M.T.Khan Road, Karachi – 75530, Pakistan
(t) +92 21 5686001-16
(f) +92 21 5633970
mailto:hafeezurrehman@dawoodgroup.com

Title	Anticipated completion Date
Designate the person responsible and establish the organization for managing Project EMP and Environmental, Health and Safety (EHS) performance of the project, including activities undertaken by contractors and other third parties (maintenance staff) as well as any on-site staff	03/30/2015
Incorporate appropriate and relevant EMP obligations in the contracts with EPC contractors and O&M contractor, including detailed timelines for implementation of specific mitigation measures and monitoring activities.	03/30/2015
Develop HR policy and procedures for in line with IFC Performance Standard 2. They should address employees’ workers rights related to wages and benefits, working conditions, terms of employment, the principle of equal opportunity, fair treatment and non-discrimination, grievance mechanism.	03/30/2015
Develop and include EHS and labour provisions and compliance conditions in contracts which will provide contractors with clear guidelines on labour performance.Develop and implement contractor control system to monitor and enforce contractors and sub-contractors’ compliance with labour conditions.	03/30/2015
Retain an Independent Ornithological Expert and develop and implement a detailed bird/bats monitoring program in consultation with the relevant governmental agency / NGO in Pakistan	03/30/2015