31543 - Karadzhalovo SPP

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Environmental & Social Review Summary

Project Number

31543

Company Name

ACWA POWER CF KARAD PV PARK EAD

Date ESRS Disclosed

Jan 20, 2012

Country

Bulgaria

Region

Europe

Last Updated Date

Jun 12, 2021

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Mar 8, 2012
Signed : Mar 9, 2012
Invested : Mar 28, 2012

Sector

Solar - Renewable Energy Generation

Industry

Infrastructure

Department

Regional Industry INF LAC & EUR

Project Description

The project involves the development, construction, operation and maintenance of a 60.4 MWp (50MW-AC effective) solar photovoltaic power plant at Karadzhalovo in the municipality of Parvomay, Plovdiv District, Bulgaria (“Karadzhalovo SPP” or the “Project”). The Project is owned by ZBE Partners EOOD (the “Company”), a special purpose vehicle that is ultimately 100% owned by SunEdison LLC, a leading global developer, EPC contractor and operator of utility scale, commercial and small size solar power systems. All of the output generated by the Project will be sold to the national electricity company, Natsionalna Elektricheska Kompania EAD (NEK), a 100% subsidiary of the Ministry of Energy Economy and Tourism under a 20-year PPA. IFC investment would be an IFC A Loan of €45 million and an IFC B Loan of up to €45 million which will be participated by UniCredit Bank Austria AG.

The Project will have 42 photovoltaic blocks of variable capacity, and each block consists of a number of photovoltaic modules (solar sub-arrays) grouped in strings and connected to an AC/DC inverter transformer station. Photovoltaic modules will be crystalline silicon (c-Si) based modules. The modules will be made up of a number of solar cells, with cell types either mono-crystalline or polycrystalline, both suitable and proven for large photovoltaic power plants. The 42 inverter stations will be connected through an internal 20kV underground network in a ring configuration which leads to a new 20/110kV substation to be built within the project site. The generated power will be transferred through a 7.5km 110kV underground transmission line (to be built as part of the Project) to NEK’s existing Borisovgrad substation

The Project site is a 100 hectare land, formerly owned by the Parvomay Municipality and used for agricultural purposes in the past. The agricultural status of the project site was re-zoned under the Municipality’s Master Plan and the land was converted to industrial use in 2006. Through a public tender procedure initiated by the Parvomay Municipality, this land was transferred to INTERZONA Ltd. Plovdiv. In September 2011, the land was sold to the Company for the Project. The site is about 160 km southeast from the capital city Sofia, or about 9km east from the town center of Parvomay. The site is flat and easily accessible from Karadzhalovo Village. There is a railway passing adjacent to the site border (southside), but sufficient distance is kept to avoid any possible shading influence on the solar modules. The closest residence is about 500 m south from the project site. The construction of the Project started in September 2011 and is expected to finish by the spring of 2012.

Overview of IFC's Scope of Review

Documents reviewed:
- Report for Ecological Assessment, Detailed Development Plan for Change of Permanent Use of Regulated Land Plot I to Regulated Land Plot XXVII, Quarter 119 (Property #000119, According to the Map of Restored Ownership) in Karadzhalovo Village, Municipality of Parvomay, Plovdiv District with the Objective of Constructing a Photovoltaic Power Plant with Capacity of up to 50MW”, Investor: INTERZONA Ltd. Plovdiv, Contractor: General partnership Hidroecostroy – Grozev and Partners, Plovdiv, March 2011
- Report for Assessment of the Degree of Impact on Protected Zone “Maritsa Parvomay” by “Detailed Development Plan for Change of Permanent Use of Regulated Land Plot I to Regulated Land Plot XXVII, Quarter 119 (Property #000119, According to the Map of Restored Ownership) in Karadzhalovo Village, Municipality of Parvomay, Plovdiv District with the Objective of Constructing a Photovoltaic Power Plant with Capacity of up to 50MW.”, Investor: INTERZONA Ltd. Plovdiv, February 2011
- Ecological Assessment Statement issued by RIEW on May 4, 2011
- SunEdison’s environmental and social due diligence documents for the Karadzhalovo Photovoltaic Power Project
- SunEdison’s corporate environmental and social management system information (obtained from IFC’s earlier, related investment in SunEdison -- #28053)

Site visits: Visits to the project site, access road, connecting transmission line route, conducted by IFC staff in November 2011

Meetings and Discussions in November 2011:
- SunEdison’s project team officers in charge of environmental and social assessment and management, including energy and environmental lawyers from Wolf Theiss law firm in Bulgaria (who conducted environmental legal due diligence at the request of SunEdison)
- Karadzhalovo Photovoltaic Power Station construction management team officers (SunEdison, Sienit, ABB)
- Municipality of Parvomay officials (including the Mayor and an officer in charge of land zoning)
- Sienit Holding, the main EPC subcontractor and an affiliate of Interzona Ltd. Plovdiv, which initially handled environmental assessment and community engagement
- Bulgarian Photovoltaic Association’s representatives
- Regional Inspectorate of Environment and Water – Plovdiv (RIEW Plovdiv)
- An environmental organization (Green Balkans)
- Lender’s technical advisor (Fichtner GmbH + Co KG)

E & S Project Categorization and Applicable Standard

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

- Performance Standard 1: Social and Environmental Assessment and Management Systems
- Performance Standard 2: Labor and Working Conditions
- Performance Standard 3: Pollution Prevention and Abatement
- Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources.

The remaining Performance Standards are not applicable or minimally relevant as explained below:

PS4: Community Health, Safety and Security
Due to the inherently small risk of photovoltaic power project both during construction and operational phases, and sufficient distance to nearby residential dwellings, no major health or safety impacts or risks on local communities are anticipated and therefore PS4 does not apply.

PS5: Land Acquisition and Involuntary Resettlement
The project site was previously owned by Parvomay Municipality and was converted from agricultural land to industrial use in 2006. There was no physical relocation of people required. The site was used by some farmers for grazing purpose, but due to the zoning change of the municipality land, those farmers were provided alternative pasture land satisfactory to them, and therefore PS5 does not apply.

PS7: Indigenous Peoples:
There are no indigenous peoples or communities in the area that will be affected by the Project.

PS8: Cultural Heritage:
The Ecological Assessment report shows that there are no registered historical, archaeological and architectural monuments within the project site and therefore PS8 does not apply. The Company will conduct monitoring of possible historical findings during the excavation works.

This is a category B project because only a limited number of specific environmental and social impacts may result from the construction and operation of the photovoltaic power plant and the short associated transmission line. However, these can be avoided or mitigated by adhering to recognized performance standards, guidelines, design criteria and specific mitigation measures recommended by the environmental assessment. While the project site is located in the Maritsa ParvomayNatura 2000 protected zone, it is of no significant conservation or habitat value because (i) the project site (about 100 ha) is a small portion of the entire protected zone (about 1%), (ii) the project site had been converted to industrial use two (2) years before the establishment of the protected zone and (iii) the environmental assessment shows that no sensitive species of fauna (avian or terrestrial) or flora will be affected. The routing of the underground transmission line is mainly along the existing municipality roads with minimal environmental or social impacts. One of the largest solar power plants in Europe, the Project will generate solar electricity contributing to the reduction of greenhouse gas emissions.

Environmental and Social Mitigation Measures

PS1: Social and Environmental Assessment and Management Systems

INTERZONA Ltd. Plovdiv, the previous owner of the project site, retained an independent environmental consulting firm (Grozev and Partners, Plovdiv) and biodiversity experts (Associated Prof AndonDarakchiev and Biologist DobromirGanev) to carry out (i) an ecological assessment and (ii) an assessment of impacts on the protected zone, in accordance with the Bulgarian Environmental Protection Act and Biological Diversity Act. Both assessments were necessary since the project site is within an environmentally protected zone called “Maritsa-Parvomay” under the Bulgarian Biological Diversity Act and EU Birds Directive (Council Directive 79/409/EEC) / Natura 2000 network of protected areas across EU. Further details are provided in the section under PS6. The assessment of impacts on the protected zone (“Protected Zone Impact Assessment Report”) dated February 2011, and the ecological assessment (“Ecological Assessment Report) dated March 2011, were reviewed by the Bulgarian local environmental regulator (Regional Inspectorate of Environment and Water – Plovdiv, or “RIEW-Plovdiv”). RIEW-Plovdiv issued a document titled Ecological Assessment Statement on May 4, 2011, confirming that the Project’s environmental impacts, including those on the protected zone, are minimal, and that the Project is compliant with the environmental legislation. The Statement included specific mitigation measures and monitoring programs to be implemented by the Company. This Ecological Assessment Statement was uploaded to RIEW – Plovdiv’s website (http://www.plovdiv.riosv.com) for public review.

The assessment analyzed an alternative site which had several advantages to the selected site – closer distance to the existing substation for connection to the grid, no high groundwater, greater distance from the Maritsa River but this site was not selected due to disadvantages including the site being a smaller area, land being used for agricultural purposes, and the location in the heart of the protected zone.

Various recommendations for mitigation measures were made in the Ecological Assessment Report and the Protected Zone Impact Assessment Report, and RIEW’s Ecological Assessment Statement listed key measures as specific project requirements. Most of other measures are being incorporated into the Project design. Additional actions necessary to meet the IFC Performance Standards will be implemented by the Company as described in this ESRS.

The Project is being developed by SunEdison’s team based in Madrid, Spain. MEMC, a global leader in the manufacture and sale of wafers and related intermediate products to the semiconductor and solar industries, acquired SunEdison in 2009. Based on MEMC/SunEdison’s mission and vision on environmental and social sustainability, SunEdison’s team in Spain and the Company established to develop the Project are committed to implement the Project under the project level environmental, health and safety (EHS) management system. During the construction phase of the Project, the Company is working with the contractors to ensure that the mitigation measures required by RIEW – Plovdiv are fully implemented, including health and safety measures and monitoring.

The Company is conducting relevant monitoring activities including (i) maintenance level of construction and transportation equipment, (ii) noise levels from construction works, (iii) waste disposal and spill prevention of fuel and lubricants.

For the operational phase of the Project, the Company will assign an officer whose responsibilities will include community engagement and EHS management (policy, procedures& programs).During the operational phase, the EHS officer will work with the O&M Contractor to establish an adequate organizational structure to manage the mitigation measures and monitoring programs (e.g. monitoring of impacts on the surface water drainage system of the site, groundwater levels and the overall vegetation to confirm that the Project’s impacts are mitigated), including clear line of responsibilities and reporting structure. Necessary EHS training programs for the relevant people operating the Project will be provided for the operational phase. The Company will also establish a grievance mechanism to receive and facilitate resolution of concerns and grievances about the Project’s environmental and social performance.

The Company will ensure that the Project and its activities implemented by subcontractors comply with Bulgarian national and local regulations related to EHS aspects and the relevant World Bank Group EHS Guidelines (environmental, occupational health and safety, community health and safety, and construction and decommissioning).

PS2: Labor and Working Conditions

The Company (special purpose vehicle) itself does not expect to have employees and its human resources practices will be in line with an already established MEMC/SunEdison Human Resources (HR) Manual and the relevant EU requirements including HR policy, working conditions and terms of employment, workers’ organization, non-discrimination and equal opportunities, grievance mechanism. As part of IFC’s investment in the Project, the Company will establish an HR Policy consistent with IFC’s PS2.

The construction of the Project is undertaken by an EPC (Engineering, Procurement and Construction, or “EPC”) Contractor – SunEdison Spain Construction S.L.U.- and two main subcontractors:Sienit (General Subcontractor) and ABB (which will build a 20/110kV substation and the 7.5 km 110kV underground transmission line). The EPC Contractor and its subcontractors have their own health and safety management system including a dedicated health and safety officer. Construction started in September 2011 and is expected to be completed by the spring of 2012. Up to approximately 450 workers will be working onsite during the peak period of construction. Workers are provided with Personal Protective Equipment (PPE) and necessary training on the safe handling of heavy equipment and installation works. Health and safety performance is monitored and corrective actions are implemented as appropriate. As of November 2011, one injury occurred due to mishandling of crane equipment, and the Company implemented necessary actions to prevent similar accidents. The Company will ensure that the O&M Contractor will adopt the high level of health and safety standards in line with IFC PS2.

It is expected that the Project will generate additional job opportunities (e.g. cleaning of solar modules, grass cutting of the project site, and other supportive services required by O&M contractor). The Company will make its best efforts to ensure that such job opportunities will be first provided to local villagers.

PS3: Pollution Prevention and Abatement
The construction and operation of the Project will have limited emissions and effluents and does not include hazardous processes or adverse impacts on the surrounding communities. No significant quantities of hazardous materials and waste are expected to be generated during construction or operation. Small quantities of metal waste from the installation of solar modules will be collected or delivered to licensed waste management companies.Processed oil, if any, will be stored in special containers, which will be delivered to specialized companies for neutralization. During the operational phase, small amounts of general non-hazardous waste will be generated by operational personnel. This will be collected in plastic bags and periodically disposed through the Karadzhalovo Village or Parvomay Municipality waste collection system.

In addition, based on the environmental assessment conducted, and SunEdison’s operational experience of similar projects, the Company is implementing the following mitigation measures to minimize pollution to the environment: (i) installation of chemical toilet for construction workers / security guards; (ii) return topsoil within the project site after photovoltaic installment works (here only minimal quantities of topsoil have been removed); (iii) maintenance of the grass under the photovoltaic panels without using any chemicals; and (iv) spill prevention of fuels and lubricants.

The Company plans to use water about twice a year to wash the solar panels. The water will be treated (i.e. water of lower hardness quality will be used to avoid stains on surfaces and temperature will be controlled to avoid panels materials stress due to temperature differences between cleaning water and module surface), and will be transported to the site by trucks. Some adjustment to the drainage route will be made within the site, but panel washing, and installment of the panels themselves, is not expected to alter the drainage system of the site significantly. The Company will also prepare and implement a landscape plan (e.g. green belt or planting low-growing trees) with effect to visually isolating the plant as necessary, while providing additional habitats, as recommended by the Ecological Assessment Report.

The Project is expected to generate about 76GWh of electricity per year. Bulgaria’s current greenhouse gas emissions performance of the electricity generation is 492 gCO2/kWh (grid average, 2007-2009 average, according to the latest 2011 International Energy Agency Statistics). Using this factor, generation of 76GWh per year is estimated to reduce approximately 37,400 tons of CO2/year.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The project site (about 100 hectares) is located within the “Maritsa Parvomay” Protected Zone with an area of 11,505.23 hectares established under the Bulgarian Biological Diversity Act and EU Natura 2000 (BG0002081) which is a part of the national and EU network of protected areas. The “Maritsa Parvomay” Protected Zone is in protected zones under Article 6, par. 1, item 3 and 4 of the Bulgarian Biological Diversity Act, and in Natura 2000’s Protection Zone based on EC Bird Directive (Council Directive 79/409/EEC on the protection of wild birds). Natura 2000 is a network of protected areas across the EU, established in 1992 and consists of (i) Protection Zones which are high level protected sites classified in agreement with the Birds Directive (Council Directive 79/409/EEC) and (ii) Areas of Conservation which are protected sites assigned under the Habitat Directive (Council Directive 92/43/EEC). The Maritsa Parvomay Protected Zone is designated as a Protected Zone under the EC Birds Directive.

The Protected Zone of Maritsa Parvomay was also declared by the Bulgarian Minister of Environment and Water on December 11, 2008 with the goals of (i) conservation and maintenance of the habitat of the described bird species for reaching their favorable environmental protection status, and (ii) restoration of the habitat of bird species for which improvement of their environmental protection status is necessary.

The Protected Zone Impact Assessment Report has the following key conclusions: (i) the Project will not affect localities and habitats of rare, endemic and other plant and animal species listed in the Biological Diversity Act, (ii) minimal negative impact is expected on some protected bird species (e.g. short-toed hawk, sparrowhawk, long-legged buzzard, common buzzard, black spike kestrel, white stork, great egret, grey heron, lapwing, kingfisher, white-fronted shrike, pipit, red-backed shrike, and red foreheaded shrike), (iii) other birds and habitats in the protected zone will not be impacted, (iv) habitat loss and fragmentation of populations of bird species subject to protection and deterioration of their structure cannot be expected, (v) the Project and other land use change projects will affect about 141.5 hectare or 1.23% of the protected zone “Maritsa Parvomay”, and the Project itself (115.4 hectare) will affect 1.004% of the whole zone.

Based on these findings, the Report concluded that the Project, including both the construction and operation phases, will not have a significant and noticeable impact on the purpose of conservation in a protected zone “Maritsa Parvomay”, and there will not be an irreversible effect on the types of birds included in the scope of protection and their natural habitats. The Protected Zone Impact Assessment recommended a bird monitoring program during the operational phase, which was included as one of the monitoring programs required by RIEW – Plovdiv’s Statement.

The Company has instructed the EPC Contractor to implement the following mitigation measures to minimize impact on habitats: (i) placement of solar panel modules is designed in a way to keep the natural vegetation to the extent possible and to allow free migration of small animal species, (ii) the area under the photovoltaic panels will not be covered with aggregates, (iii) no use of chemicals to control grass under the photovoltaic panels, (iv) the construction and installation works will be performed outside the active breeding period of species (April to June), (v) the fence of the facility will provide for passages for small wild animals typical for the region, to allow migration and use of the site as a habitat. The Company will monitor the implementation status of these mitigation measures.

There are some examples of photovoltaic power plants where sheep grazing among the module rows is allowed, partly to avoid the use of grass mowers, and partly to harmonize solar generation with agricultural activities. The Company is considering whether this option can be feasible at the project site.

Stakeholder Engagement

During the preparation of the Ecological Assessment Report and the Protected Zone Impact Assessment Report, various parties were informed of the Project, its potential environmental and social impacts and proposed mitigation measures. RIEW’s EA Statement issued on May 4, 2011 confirms that no written objections were raised. The Mayor of Parvomay Municipality explained to IFC that various town hall meetings were held about the Project and he confirmed that the Project is well supported by the Municipality. It is understood that some farmers who could use the municipality owned land for grazing purposes expressed some concerns, but the Municipality offered alternative pasture lands for grazing to their satisfaction. The parties consulted include: Municipality of Parvomay, Town Council of Karadzhalovo village, Regional Inspection of Environment and Water – Plovdiv (RIEW Plovdiv), Regional Health Inspection – Plovdiv, River Basin Directorate – Plovdiv, Ministry of Environment and Water – Subsurface and Underground Resources Department, Bulgarian Society for the Protection of Birds, Green Balkans Federation Plovdiv. Green Balkans (an NGO active on protected zones in Bulgaria) expressed satisfaction with the conclusion of the two Reports to IFC in November 2011.

SunEdison’s representative stationed at the Karadzhalovo project construction site is actively handling inquiries from the affected communities to ensure that concerns, if any, are properly and promptly addressed.

Ecological Assessment Report, and Protected Zone Impact Assessment Report listed below are available at Karadzhalovo Photovoltaic Power Station construction site for review. The same set of documents is attached to this IFC’s ESRS.

- Report for Ecological Assessment, Detailed Development Plan for Change of Permanent Use of Regulated Land Plot I to Regulated Land Plot XXVII, Quarter 119 (Property #000119, According to the Map of Restored Ownership) in Karadzhalovo Village, Municipality of Parvomay, Plovdiv District with the Objective of Constructing a Photovoltaic Power Plant with Capacity of up to 50MW”, Investor: INTERZONA Ltd. Plovdiv, Contractor: General partnership Hidroecostroy – Grozev and Partners, Plovdiv, March 2011
(Bulgarian and English)

- Report for Assessment of the Degree of Impact on Protected Zone “Maritsa Parvomay” by “Detailed Development Plan for Change of Permanent Use of Regulated Land Plot I to Regulated Land Plot XXVII, Quarter 119 (Property #000119, According to the Map of Restored Ownership) in Karazhalovo Village, Municipality of Parvomay, Plovdiv District with the Objective of Constructing a Photovoltaic Power Plant with Capacity of up to 50MW.”, Investor: INTERZONA Ltd. Plovdiv, February 2011
(Bulgarian and English)

Further information can be obtained at:

Mr. Alessandro Ceschiat
Project Manager
ZBE Partners EOOD
c/o SunEdison
Calle de Alcala 44/3
28014 Madrid
Spain

mailto:aceschiat@sunedison.com
Tel: +34 915242636

Client Documentation

File Name	Actions
Protected Zone Impact Assessment-Bulgarian.pdf
Protected Zone Impact Assesment-English.pdf
Ecological Assessment-English.pdf
Ecological Assessment-Bulgarian.pdf

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

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Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

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