The Project is located on ridges of three adjacent hills, which are covered with low plants; there is limited agricultural and grazing activity in the project area and there are no other economic activities at the proposed site and its immediate vicinity. Proximity to the nearest settlement is approx 700 meters. The proposed project site is located in a newly established Croatian Eco Network zone, which will serve as a basis for establishing the Natura 2000 ecological network in Croatia. Notwithstanding, the sites are not located within boundaries of any protected zones, i.e. National Park “Krka”, protected landscape “Cikola” and special reservation “Prukljansko Jezero” are all located approx 10 km westwards from the project site.
RP Global will conduct its activities in accordance with EIA, environmental management and monitoring plan (EMMP) and terms set in the environmental approval and will, upon implementation of the EMMP and specific additional measures described below, which will be summarized in IFC Environmental Social Action Plan (ESAP), comply with the IFC Performance Standards on Social and Environmental Sustainability.
PS1: Social and Environmental Assessment and Management System
Social and Environmental Assessment
The proposed wind farm is one of 14 location prospects in Sibensko-Kniska Zupanija (Province) endorsed by the Croatian Government. The Provincial Spatial Plan envisages the development of energy generation projects, including wind farms; selection of site was based mainly on the general appreciation of area from the accessibility point of view, wind availability and some other preliminary criteria. Based on this Plan around 28 potential wind farms projects are identified including the project site(s), which is territorially spread among municipalities of Sibenik, Drnis and Unesic.
Selection of the project site was a result of alternative site analysis including (i) availability of wind resources, (ii) assessment on landscaping and visual impact as the region is part of the Croatian coastal tourist area (iii) noise impact to local communities, (iv) access to the site and relative vicinity of the National electric grid station point, (v) vicinity to human settlement, (vi) location of protected areas or water courses in the Project’s area and (vii) the community’s interest in exploring the use of renewable.
Currently three wind farms are operational in the relative vicinity of RP Global development; the client’s Supplemental Report to EIAs, prepared in March 2012, assessed the potential for cumulative impacts in relations to (i) avifauna and bats i.e. potential for mortality due to direct collisions with or pressure changes in the close vicinity of the rotor blades during operation of the turbines, disruption of migratory routes and flight pathways and barrier effects reducing available flying space, (ii) landscape and visual impacts, and (iii) noise impacts. Cumulative impact of the project has 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 RP Global will appoint an Independent Ornithological Expert (IOE) who will have the responsibility to undertake bird monitoring and survey on the site, including wintering, breeding and migratory bird surveys in line with National Guidelines for EIA for Wind Farms and the EMMP as elaborated in more details under the PS6. For any future extension i.e. development of the second stage of up to 88 MW, RP Global will ensure that cumulative impacts at this site are assessed and mitigated in a manner consistent with the IFC Performance Standards.
Several Wind studies have been separately carried out for “Bubrig” / “Crni Vrh” and for “Velika Glava”, the most recent one from Megajoule, a specialized Portuguese wind energy firm made the assessment for the 1st Stage – 19 x E82 on Velika glava, Bubrig & Crni vrh. The report indicates an average long-term wind speed at hub height of 7,3 m/s. It is based on 7 years of wind data from the 40m tubular mast installed on site and 9 months of data from the 2 new 80 m towers. Also as part of licensing process i.e. applying for (i) location permit and (ii) building permit to MoEnv, an updated noise impact assessment was performed in 2011.
RP Global prepared the EIAs for Velika Glava and Bubrig / Crni Vrh in 2005 and 2007, respectively; as the project’s installed power is in range above the 20 MW threshold the State MoEnv was responsible for the project information disclosure and public consultation process. The EIAs assessed the Project’s potential environmental and social impacts including migratory birds collision, noise, health and safety, shadow flickering, visibility, air emissions and solid waste management (construction phase), delivery of equipment, construction of foundation for cranes and tower foundations, tower assembly and installation, historical heritage. Following the successful completion of the process, including the project documentation disclosure and consultation for both wind farm locations in Sept 2005 and April 2007 respectively, a Committee set up by MoEnv has reviewed the EIAs and issued the location permit for the project in October 2010. Consequently due to changes to the original equipment specification, for which the first location permit was issued, the sponsor had to re-apply for the new location permit, which was obtained in July 2011.
At IFC’s request, RP Global prepared updated supplements the original EIA studies by: (i) additional baseline bird/bat studies to ensure that this aspect is satisfactorily covered: and (ii) developing a detailed overview on the stakeholders engagement. This Supplemental Environmental and Social Impact Report was prepared by the sponsor in March 2012. According to the findings of the Supplemental Report all concerned stakeholders supported the project and provided assurances that any potential negative impact to biodiversity is only minimal and that it can be managed through appropriate EMMP. The Report suggested that an additional round of site bird and bats surveys be done before the construction starts and any resulting mitigation measures be made part of the main project design, including provision for a shutdown plan to ensure no significant impact on population viability especially during the migration period. This action is appropriately addressed trough EMMP. Important element of the EMMP includes establishment of an ongoing 2 year independent avian monitoring plan. Mitigation measures to minimize avian collisions are summarized under PS6 below.
Management and Monitoring Program
As part of the Supplemental Report, an EMMP was developed consisting of the organizational structure and roles and responsibilities, mitigation plan, monitoring plan, communication and documentation and environmental training. The mitigation plan is a key component of the EMMP. It lists all the potential effects of each activity of the project and their associated mitigation measures identified in the EIA. 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. Relevant mitigation measures will be translated into environmental and social development requirements and made part of the contracts for the construction activities. The EMMP will be modified and updated by construction contractor and O&M operator. Major mitigation measures for identified potential impacts are summarized under relevant PS section below.
Organizational Capacity
RP Global will establish the environment, health and safety structure and develop and implement the EHS and socioeconomic management system. At a minimum there will be an in-house specialist responsible for overseeing and monitoring the entire implementation of the EIA and EMMP. The EMMP as well as environmental management requirements and specifications will be included in all contracts with contractor(s), which will be required to appoint a dedicated field EHS manager at the project site.
Environmental and social trainings will help to ensure that the requirements of the EIA and EMMP 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. The primary responsibility for providing training to all project personnel will be that of the RP Global. The scope of the trainings will cover general environmental awareness and the requirements of the EIA and the EMMP, including (i) general environmental and socioeconomic awareness; (ii) environmental and social sensitivity of the project area; (ii) key findings of the EIAs; (iv) mitigation measures; (v) social and cultural values of the area 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 RP Global, as needed.
PS2: Labor and Working Conditions
RP Global will establish a written HR Policy and will provide access of this to all staff, both employee and non-employee workers. The RP Global HR policy and procedures will be in line with Croatian Labor Law and 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
Besides its own workforce, the contractor(s) may need to subcontract additional workforce locally, hiring of which will be in accordance with Croatian Labor Law. The construction contractor 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.
Occupational Health and Safety
The EMMP Plan is designed to manage the health and safety and environmental performance; responsibility for implementation of EMMP will be with RP Global. Integral parts of the RP Global’s EMMP will be (i) the construction contractor and (ii) O&M contractor HSE Plans. These HSE Plans include management systems, health, safety and environmental programs, roles and the responsibility and site procedures, among others provisions.
The Construction Contractor is expected to be local reputable company that applies the best industry practice in construction i.e. HSE Plan, which is a legal obligation to have in place for each project that contains occupational safety and health procedures including use of personal protective equipment, working procedures for various types of construction work and equipment movement. All employees will be provided with the necessary EHS training and safety equipment as required for their respective responsibilities and duties. 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 and will be part of the HSE plan. 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. There will be no accommodation on site as the work force will be hired.
Enercon, an equipment supplier and O&M operator, maintains a corporate ESMS. Best practice international standards will apply 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 EHS training specific to the project and safety equipment as required for their respective responsibilities and duties. All contracts with contractors and subcontractors will include a clause requiring compliance with the EMMP and PS2.
During the construction phase RP Global will have the primary responsibilities for managing EHS impacts through its own EHS staff and via an ongoing coordination with the contractors’ EHS managers to ensure that the project is in compliance with the EIA and EMMP throughout the project construction. RP Global will also coordinate with relevant government departments and other stakeholders on any matters related to the EHS aspects of the wind farm construction. The contractors’ EHS Managers will assume the main responsibility for all EHS and social matters pertaining to their works i.e. will be responsible for the implementation of the EMMP during construction works, (ii) communication with and the training of their respective construction and camp crews in all aspects of the EMMP.
During the operation phase of the project, management of EHS and social development aspects will become a routine function, as an integral part of the O&M activities. RP Global through its EHS staff 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
The project is a net benefit from air pollution perspective as it will generate electricity from renewable resource. Environmental impacts during the construction works will be temporary in nature. During the construction phase RP Global through its main contractor(s) will ensure that the project is developed according to National Guidelines for Wind Farm development, EMMP, IFC EHS Guidelines for Wind Project and good industry practices.
Construction phase
The turbines will be positioned in northwest – southeast direction perpendicular to the prevailing wind direction following the contours of hill ridges to obtain higher wind speeds; distances between individual turbines are ranging between 300 – 400 meters.
The construction site will be set up with all amenities and temporary facilities for the workforce to provide for safety and health at the site. Existing local roads will be expanded and used for the project i.e. truck loads of construction material, ready-mix concrete, turbine parts, etc. New access roads to individual turbines will be established. Road construction and expansion, digging or blasting for turbine foundations and transformer station will require proper drainage and erosion management; for this a specific contractor actions and responsibilities will be set in the EMMP. Excavated material generated during construction of the wind farm will be reused for local landscaping and internal roads construction. Any land that will be disturbed and excavated during construction will be re-contoured and returned to its original state as much as possible. Existing roads, if used for underground cabling purposes (between turbines and the substation) will be reclaimed to their original state after cable installation.
A limited quantity of general waste will be generated during construction and maintenance (packaging, metals, plastics, filters, oils etc.), which will be disposed of in designated places, collected by licensed contractors and/or recycled where possible. As part of the contractor’s construction management plan a hazardous materials management procedure will be established during the operations phase 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.
Temporary on-site sanitary facilities will be established. Water needed for construction and potable water will be provided either directly from the nearby village, without impacting potable water availability for the village itself or supplied periodically by truck in a plastic tank.
Diesel generators will be used for power to operate the construction equipment and for any other on-site requirements, like welding. Emissions from the generators will be minimized by ensuring that the engines are always properly tuned and maintained. Construction machinery and vehicles will use low sulfur content diesel fuel.
Noise impact may at times be significant on the surrounding households, located approx 700 meters from the site, during the construction activities and from traffic generated by the construction machines and trucks passing through local roads on their way to and from the project site. To avoid such situations during the construction phase the contractor will develop procedures to control ambient noise at nearest receptors through selection of adequate low-noise producing land-based equipment, including compressors and generators. There will not be night-time construction activities with the exception of erection of turbines because of e.g. weather conditions; RP Global will make sure that the noise pollution during the night work does not exceed National and IFC night time noise level guidelines. Vehicles and construction machinery have to comply with EU Directive 2000/14/EZ that refers to noise emission generated from land based machines. Noise pollution from the generators and other heavy construction machinery and its negative impacts on the workforce will be mitigated by obligatory use of PEE. The Construction contractors will be instructed to avoid excessive and prolonged activities on e.g. blasting, excavation during the period between March and July to avoid disturbances to the nesting birds.
Operational Phase
O&M activities will not be very extensive. This will include mainly normal periodic maintenance activities. There will be no residential staff at site. Due to the big distance between the turbine and the closest settlement noise impact is not expected to be significant. Based on additional noise impact assessments on 6 reference points, taking into account various wind speed regimes, (settlements Aužine, Bralići, Mišure, Slamići, Smolići i Maleši) day and night time noise has been assessed to be within the max allowable guidelines as per IFC Guidelines. For turbines that potentially may negatively impact the most affected households at wind speeds above 8 m/s, noise can be controlled through the use of variable speed turbines or pitched blades to lower the rotational speed.
Annual GHG emission displacement is estimated at 33.300 ton CO2 per year, based on the Croatian’s grid average greenhouse gas (GHG) emissions performance per unit of electricity generation of 0.3414 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 nearby communities are likely to be moderate due to the relative distance from the project location. Excavation of land, construction work and traffic will generate a certain quantity of dust which will be managed through use of water sprayers to minimize fugitive emissions. This activity is important given the fact that some of the households are located around 700 m from the individual turbine foundations and other working sites and local roads.
The vehicular traffic on the local roads can potentially pose a certain level of adverse impact as it will involve moving of heavy machinery, loaders, bulldozers and trucks and transport of equipment, raw materials, construction waste and construction of new roads that will enable access to each individual turbine. The turbines will be transported from the port of Sibenik or Zadar to the project site. Each of the 19 turbines that will be erected will involve 10 transports, including special long vehicle transports. To mitigate negative impact and manage the traffic appropriately a Traffic Management Plan including a strict code of conduct for the construction workers and drivers, posting road signage at appropriate locations to reduce safety hazard and promoting defensive driving in sections where the road passes near / within the communities, will be developed to ensure that the movements are phased and the hours of movement limited to the working day. In addition, the movement of construction vehicles will be routed to avoid residential areas where possible, thereby minimizing potential noise and dust impacts. Specific measures will be designed for contractor management, with specific focus on truck fleet maintenance, cleaning/washing of ready-mix concrete truck after pouring of concrete in the designated foundation/place, and before driving back to off-the site concrete plant, cleaning of tires prior to the entering the road in use by public transport and driving behavior and training. RP Global will inform all local communities about this plan and make the plan available locally. During operation it is anticipated that vehicular access to the wind farm will be minimal and related only to periodic maintenance.
Fire risk is relatively high in the region as there is a history of fire outbreaks especially during the summer season. The fire protection system at the wind farm will be an integral part of the project design. This risk can be mitigated via an agreement with the local fire brigade, cutting the shrubs around the turbines, etc. The fire risk, spill control, prevention, and countermeasure plan and risks from natural elements such as earthquake, torrents will be part of Emergency Preparedness and Response Plan.
Due to the fact that the local population residing in the project area is far away from the Project site no impact or risks to the health and safety of the general public are expected from a 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 25 m/s. At speeds greater than 25 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 is planning to have protective fencing around transform station, which will also be securely locked to prevent any unauthorized entry. During the construction phase the Contractors will be responsible for access control and security procedures on the site. If needed security services will be subcontracted and managed by an established security service provider that has formal procedures and codes of conduct. Their task will be to periodically oversee the operation of the plant, conditions along the connection T-lines, around transformer station, and turbines.
PS6: Biodiversity Conservation and Sustainable Natural Resource
As a part of the EU accession process, Croatia established the National Ecological Network and Appropriate Assessment procedure. The National Ecological Network covers the areas of Croatia that have been identified as areas of importance for conservation or establishment of a favorable status of threatened and rare habitat types and/or wild tax at the European (Birds Directive and the Habitats Directive and Bern Convention) and national level. National Ecological Network was a base for preparing NATURA 2000 proposal (www.natura2000.hr).
The ecological network is defined in the Nature Protection Act (NPA) (OG, No. 70/05, 139/08, 57/11) as the system of interrelated or contiguous ecologically important areas which by their well balanced biogeography distribution substantially contribute to the conservation of the natural balance and biological diversity. In addition, the ecological network is regulated by the Decree on the Ecological Network passed by the Government in October 2007 (OG, No. 109/07). The Decree prescribes the ecological network areas with conservation objectives and protection measures aiming at maintaining or establishing a favorable status of threatened and rare habitat types and/or wild taxa.
The larger area in which the project is located, according to the Decree on the Ecological Network, is part of the internationally-recognized important area for birds (IBA) “HR1000026 Krka and nearby plateau”. The area is known to provide feeding, nesting, hunting ground for a number of birds/bats species. Also several species use the area for seasonal migration. The closest protected areas e.g. National Park “Krka”, protected landscape “Cikola” and special reservation “Prukljansko Jezero” are all located approx. 10 km westwards from the project site.
According to the results of the ornithological survey conducted in 2007, negative effects from the project development can be expected for the short-toed eagle (Circaetus gallicus), which is a nesting bird in the direct area of the plateau. It belongs to a category of threatened birds (i.e. vulnerable (VU) at national level and rare European-wide). Circaetus gallicus hunting behavior makes them vulnerable to wind turbine blades. No other bird species present in the area are expected to experience significant negative effects. Three species of endangered or rare bats known to exist in the wider project and coastal area -- Nyctalus leisleri, Miniopterus schreibersi (E) i Tadarida teniotis (Rare) – are also expected to be moderately impacted by the wind farm operations.
The 2007 survey results led to modifications in the location of at least one turbine to minimize risks to bird and bats. To further minimize the potential significant avian impact, RP Global will appoint an Independent Ornithological Expert (IOE) for the sites and commission an additional field ornithological study, which will assess the current status of the local avifauna (bird and bats) as compared to the previous Ornithological studies prepared in 2007 and determine the need for any additional prevention and mitigation measures. RP Global will implement appropriate mitigation measures recommended by the IOE based on an agreed protocol, including an adjusted operational mode resulting in temporarily shutdown of the turbines. Monitoring of birds (two visits during the April and May) and bats (monthly from March till October) will be conducted at least for the two years after the commencement of the operations using the same methodology used at the time when the first EIAs were prepared. Comparing these results will make it possible to assess the level of impact of the turbines to the viability of bird / bats population and accordingly apply appropriate measures. Consequently, if the bird / bats mortality exceeds generally accepted levels the corrective measures should be taken including, if needed, an operational mode providing a temporarily shutdown acceptable to IFC to ensure no significant impact is possible on species in question.
The findings of this study will be incorporated in the EMMP which already has a set of mitigation measures to reduce the impacts of the wind plant operation on birds and bats mortality including (i) appropriate storm water management measures that will be implemented to avoid creating attractions such as small ponds which can attract birds for feeding or nesting near the wind farm (ii) erecting wind towers at minimum distance of 300 m to avoid avian collision, (iii) placement of power and communication cables underground to reduce the chance of any avian collision, (iv) conducting bird/bat mortality counts in coordination with the local partners involved in the conservation efforts of the threatened species. Recommendations included use of anti-perching devices; painting of blades in appropriated colors to increase visibility; use of flight diverters, strobe lighting, if required.
