While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The proposed investment in the Project is a Category B project because of 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. An EIA has been undertaken for the project and a detailed EMP has been compiled for the construction and operations phases. The three affected land users have been compensated, and damage was avoided to archeological sites of interest. Stakeholders have been engaged during the project development to date and no objections were raised to the environmental authorization issued by the Croatian Government.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

At the policy level, AE uses, and is guided by Acciona’s corporate E&S policies, including a core Quality and Environmental Policy, a Social Action Policy, Biodiversity Policy, Health & Safety Policy, Responsible Procurement Policy and Human Resource Strategy 2011-2013. AE applies Acciona’s Code of Conduct for its employees and a set of Ethical Principles for its suppliers, contractors and collaborators which lay out the company’s core expectations on issues including human resources, sustainability, corporate governance and human rights. AE has a well-established and certified Integrated Management System (IMS) incorporating Quality (ISO 9001), Environment (ISO 14001) and Health & Safety (OHSAS 18001). AE extends its IMS to each new site, including Jelinak WPP.



A comprehensive EIA was carried out for the project by Oikon (Croatian Institute of Applied Ecology). The EIA identified a number of sensitive species and sites and led to certain design modifications, e.g. relocation of two turbines away from archaeologically sensitive sites. The EIA is disclosed together with this ESRS. The nearest existing wind farms to the site are Orlice (9.5 MW, 12 km away) and Glumca (22 MW, 9 km away). Given the distances involved and the small size of these wind farms, potential cumulative impacts are deemed negligible, especially as the Jelinak WPP does not involve construction of any new transmission lines. However, as mentioned under the PS 6 section below, bird monitoring data will be made publically available in order to further the understanding of any potential cumulative impacts in the broader project area.



The EIA approval letter from the Ministry of Environmental Protection, Physical Planning and Construction (Jan 9, 2009) contained a series of clear requirements that the Sponsors were required to implement. A hard copy brochure was developed for distribution to all workers, containing environmental and social site instructions and a clear map of sensitive sites and what to avoid. Eurus, an engineering consultant retained by AE, developed and is currently implementing a construction- and operations-phase EMP based on the Ministry’s requirements and AE’s internal E&S requirements. The Jelinak EMP is disclosed together with this ESRS.



AE’s QSE Department is headed by a Director who works with an Occupational Health & Safety (H&S) Manager, an Environmental Manager and a Quality Manager, each of which has a small team based in Pamplona and/or Madrid. These core teams provide support to international projects such as Jelinak WPP. AE has a dedicated Environmental Specialist in Spain working on international projects, including Jelinak. Site-level E&S assessment and monitoring is typically outsourced to one or more independent third party consultants who report to AE. In Jelinak WPP’s case, AE received the EIA from Oikon and commissioned a third party design and construction supervision company (Eurus) to develop and oversee implementation of the
EMP. Certain key EHS requirements were built into construction contracts and a Eurus employee spent 2-4 days per week on site during construction to oversee E&S aspects of the works and report progress and issues to AE’s Environmental Specialist in Spain. In addition to OHS provisions in each construction contract, the Sponsor appointed a third party OHS oversight company, Alpha Test, to ensure that OHS provisions were correctly implemented and reported on during construction.



Jelinak WPP has an emergency response plan in accordance with AE’s Emergency Control and Response Procedure. All personnel and contractors are trained on this plan. Emergency equipment is checked on a regular basis to ensure that it is available should an emergency occur. The emergency procedure mentioned above defines the interval required for conducting emergency drills at each of AE’s facilities.



The EHS performance of Jelinak WPP is being monitored by consultants Eurus, in accordance with the project EMP. Monitoring data, such as noise levels, bird and bat mortality, status of archaeologically sensitive sites and complaints, are reviewed by AE’s Environmental Specialists in Spain and reported to the regulatory authorities on a periodic basis as per Croatian law.

Acciona has Human Resources policies which, in combination with Croatian labor laws, ensure that workers will be treated in accordance with the requirements of IFC Performance Standard 2. This includes, for example, exclusion of child and forced labor, provision of written employment contracts to workers, inclusion of provisions dealing with non-discrimination and equal opportunity in all contractual documents and availability of forms of grievance mechanism for workers to raise any concerns. The company currently has only a handful of full time employees based in Croatia. Construction of the wind farm involved a workforce of approximately 30-50 workers on site at any given day, and is now complete. No workers accommodation camp was established for this project at or near the site; instead, construction workers were transported to site daily. As the operations phase workforce is very small, and as most ongoing activity on site will be implemented by contractors, it is unlikely that Acciona staff in Croatia will participate in workers’ organizations, although the Sponsor will allow them to.



Acciona has a corporate Health & Safety (H&S) Manager who also has responsibility for AE health and safety management. AE has a H&S team based in Spain as well as QSE Managers, Coordinators and/or teams in other countries, depending upon the scale of operations in each. As mentioned above, OHS matters were a contractor responsibility during the Jelinak construction phase and the Sponsors commissioned an independent third party contractor (Alpha Test) to oversee OHS implementation. Each contractor was required to develop and implement an OHS Plan, which was in turn checked by Alpha Test. There were no significant OHS incidents during the construction phase and likewise there have been no significant OHS incidents to date during the operations phase.

The Jelinak project will provide a net benefit with respect to air pollution perspective as it will generate electricity from renewable resource and displace or replace more polluting thermal power generation. Annual GHG emission displacement is estimated at 24,000 tCO2eq per annum, based upon the Croatian’s grid average greenhouse gas (GHG) emissions performance per unit of electricity generation of 0.34 tCO2/MWh (International Energy Agency, 2010) and expected generation of 70.4 GWh/year.



Environmental pollution impacts during construction were limited and temporary in nature. Waste material generation was generally limited to excavated rock and soil (utilized mainly to construct site roads and re-landscape the site), oils and lubricants from construction vehicles (parking areas were impermeable and equipped with an oil separator) and small volumes of sanitary waste (portable toilets were used as there was no site camp; waste was removed periodically to a nearby town). No fuel was stored on site.



During the operations phase, consultants will conduct noise monitoring in nearby villages (Mustre and Cudine) for a year, in accordance with EIA permit requirements. The resultant measurements will be used to validate the findings of the noise assessment report contained in the EIA, and will be compared to a one-time 24-hour noise measurement conducted in these same villages prior to wind farm operational start up. Noise monitoring information will be periodically posted in a public place during the monitoring period. If the continuous monitoring results exceed the threshold limits for the nearest residential receptors (situated around 700 m away) then the Sponsors will be required to regulate noise from individual generators to within acceptable limits.



Shadow flicker was investigated in the EIA and found not to be a significant risk due to the 700 m distance to the nearest habitation. However now that the windfarm is operational, Sponsor’s representatives will visit the nearest residences at times of the day when shadow flicker might be an issue in order to verify that these households are not disturbed by shadow flicker, and to propose mitigation if this is found to be an issue for any household. Households will also be made aware of the grievance mechanism available to report any complaints related to windfarm operation.



A radio-electric interference study was conducted for the project. As Croatia has switched to digital television, there will be no interference with analogue TV signals. Wind towers have been marked with red signal lights at a height of 45 m and at the top of each tower, so as to be visible from all aircraft approach directions. Blade tips have been marked with a 5 m wide red band for easier visibility during daylight hours.

Croatia has established a National Ecological Network which identifies areas of importance for conservation or establishment of a favorable status of threatened and rare habitat types and/or species. At the time of the EIA and environmental approval, the project did not fall within, or close to, any habitat prioritized in this Network. However, subsequently a new Special Protection Area (SPA) and Important Bird Area (IBA) known as Mosor, Kozjak and Trogir has been proposed which incorporates the project site. This site, if ratified as an SPA/IBA in future, would be designated mainly to protect the Rock Partridge (Alectoris graeca saxatillis), Golden Eagle (Aquila chrysaetos), Peregrine Falcon (Falco peregrinus) and Olive-tree Warbler (Hippolais olivetorum). are the main important species under protection.



The project site is located on a high, rocky ridgeline and is sparsely vegetated with no standing water or forest and few, if any trees. Two protected plant species, namely the Provence orchid (Orchis provincialis) and Fritilaria messanensis ssp gracilis (fritillary) were identified during the flora studies component of the EIA. In order to prevent adverse impacts on these plants, construction activities were restricted to within access and servitude road corridors and wind turbine locations. Soil and rock disposal sites, construction site works and temporary buildings were aoided near turbines 1-4 and fencing was used, in collaboration with a botanist, to ensure that these plants were not damaged inadvertently.



Detailed construction-phase bird and bat monitoring studies were required for the wind farm in order to comply with Croatian regulations. The wind farm has been designed to minimize the likelihood of bird impacts. No bird migration routes have been identified nearby to the site and there are no wetlands, forests or other high value bird habitats located in the vicinity. Bird and bat monitoring studies commenced during construction and continued for a year. These studies were sub-contracted to Oikon, the Croatian Institute for Applied Ecology. Bird monitoring during construction involved four, two day/night monitoring exercises in April, July, August and November 2012 using transects, vantage point monitoring and related methods. This monitoring revealed a low number of birds at/over the site throughout the year during construction and did not identify any of the particular endangered or vulnerable species for which the proposed SPA may be designated in future.



Given the proposed SPA status of the area, detailed bird mortality monitoring is required during operations. Under Croatian regulations, the Sponsors are required to a) monitor the local population of nesting birds, by means of transects, in April and May for at least two years; b) monitoring the populations and passage of wintering birds via at least ten, two day monitoring visits during the autumn and spring migration seasons, nesting and after-nesting dispersion, and w
intering. This will include nocturnal bird species and all habitat types; c) undertaking systematic searches for bird activity and dead birds in the vicinity of each turbine during operations, in order to estimate actual collision impacts. Monitoring results, which will be provided to the Directorate Nature Protection in Ministry of Culture, will determine whether additional monitoring is required. As per the attached E&S Action Plan, the Sponsors will use detailed monitoring data to calculate collision risk for the windfarm using a credible international model and make this information publically available in order to further the understanding of potential future cumulative impacts in the area. If adverse impacts on any endangered or vulnerable species are identified, the Sponsors will take appropriate measures to reduce or eliminate such impacts. If such mitigation measures include an offset component, the Sponsors will prepare a Biodiversity Action Plan according to IFC PS 6 requirements.



Bat monitoring during this period involved five separate field visits during the months of March – November 2012 and was focused on periods of highest expected bat activity, i.e. Summer and Autumn colony formation and migration periods. Inspections of nearby potential roosting sites were undertaken during the day and night time recordings were made using sound recorders and ultrasonic equipment. Three bat species were identified out of a total of eleven species thought to inhabit the broader area and a higher than expected number of (mainly low flying, < 25 m) bats was recorded, especially during the Summer and Autumn months. Croation regulations require that bat mortality is monitored for at least two years of operations in order to determine the mortality rate and the species involved, in line with Eurobat requirements. The Sponsors will commission independent bat experts to undertake regular and detailed collision victim survey visits for at least the first three years of operation, using internationally acceptable methods. A decision as to whether additional monitoring is warranted will be undertaken at the end of this period. If adverse impacts on any endangered or vulnerable species are identified, the Sponsors will take appropriate measures to reduce or eliminate such impacts (e.g. by modifying turbine cut-in speeds and/or turning off problem turbines during migration periods). Should offset measures be required, the Sponsors will prepare a Biodiversity Action Plan according to PS 6 requirements.

The project area forms part of a ‘cultural heritage domain’, in particular the southern slopes that lie below the wind farm itself. This domain has been recognized for its historical value due to the long-term presence of traditional grape and olive processing in the landscape and presence of old grave mounds. As a result, the EIA studies entailed detailed field archaeological studies – i.e. trenching, cleaning and documenting of sites of interest – and the Sponsor was required to have a qualified archaeologist on call at all times during construction to deal with any chance finds. The EIA approval required archaeological investigations of a number of grave mounds, sinkholes and other structures in the vicinity of the site, most of which turned out to be barren. During construction, several sites of interest located nearest to construction areas were monitored to avoid damage, in consultation with Eurus and the construction contractors. During the design phase, two turbines were re-sited so as to be further from archaeological sites of interest.



Due to the known landscape value, the EIA approval required that wind farm access roads be located on the less sensitive northern side of the ridge, away from ancient agricultural terraces, and avoided fenced arable land. Heavy vehicle use and construction outside of the approved wind farm development zone was forbidden. Damage to the historical landscape on the southern slopes of the ridge had to be minimized, and where damage to dry stone walls was unavoidable, the walls had to be re-built by hand after construction under supervision of the archaeologist. The landscape is to be returned to its pre-development state and excavated material is to be used for roads and other infrastructure construction, rather than dumped into karst sinkholes. Community access to sites of interest, e.g. burial mounds, will not be restricted by the project.

The project site is an uninhabited high ridgeline. The nearest small villages are Mustre and Cudine, the closest of which is located around 700 m from the wind farm. Project impacts on local communities are expected to be very limited, due to the fact that the project site is only minimally used for agriculture – which will continue as before during operations - and village roads were not utilized for construction purposes.

Following submission of the draft EIA to Government, appointment of a 12-member expert commission from different ministries to comment on it, and incorporation of these comments, it was released for public comment in the first half of 2008. Public meetings were advertised in newspapers one month beforehand, and were conducted in each of the two affected municipalities. The meetings followed a 21-day public disclosure period. The first public meeting was held on May 8, 2008, in Marina Municipality and the second one on May 20 in Seget Municipality. Public queries raised in these meetings had to be answered in writing and the answers reviewed by the EIA review commission to its satisfaction.

The key concerns raised by local communities included turbine noise; the need for additional faunal studies; the possible impact on cultural heritage and the potential for electromagnetic interference on television reception. The wind turbine model was changed to a less noisy type and one turbine location was altered to reduce potential noise impact; ongoing bird baseline and monitoring studies have been conducted; detailed cultural heritage studies were undertaken and an archaeologist was on call in the case of any chance finds; and an electromagnetic radiation study was completed. EIA amendments were presented to the EIA review committee in December 2008 and accepted in early 2009. Subsequent interaction with local community members has been on an as needed basis, e.g. during land acquisition and in preparation for the start of construction on site in 2012. Relations with local people appear to be cordial, though there is no formal mechanism for ongoing stakeholder engagement. The Sponsor will develop and implement a Stakeholder Engagement Procedure, including a grievance mechanism, covering the operational phase of the Jelinak project, as per the attached E&S Action Plan.

As mentioned earlier, noise monitoring results, which are likely to be of direct interest to local community members, will be posted at public places in the affected settlements during operations, along with the current wind farm power production, total generated power and the decrease in CO2 emissions due to displacement of fossil fuel generation.

An annual royalty fee of 0.01 kn per KWh will be paid to these municipalities, which should equate to about Euro 100,000 per annum once the wind farm becomes operational in 2013.

Vjetroelektrana Jelinak d.o.o.
Zrinsko-Frankopanska 54/IV,
21 000 Split, Croatia

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
1. Stakeholder engagement: The Sponsors (Acciona Energia International) will develop a Stakeholder Engagement Procedure to be implemented by Vjetroelektrana Jelinak so that key Jelinak WPP stakeholders, including nearby communities, are kept informed of wind farm developments and have the opportunity to share any views and grievances during operations and decommissioning.	06/30/2013 12:00:00 AM	Completed	Completed	06/26/2013 12:00:00 AM
1. Bird collision risk: The Sponsors will commission independent ornithological (bird) experts to use operational monitoring data to complete a collision risk for the windfarm using a credible international model. If adverse impacts on any endangered or vulnerable species are identified, the Sponsors will take appropriate measures to reduce or eliminate such impacts. If such mitigation measures include an offset component, the Sponsors will prepare a Biodiversity Action Plan according to IFC PS 6 requirements. Monitoring information, including the collision risk assessment, will be made publically available in order to further understanding of potential cumulative impacts in the proposed SPA/IBA.	07/31/2014 12:00:00 AM	In Progress	Under discussion with IFC client
1. Bat impacts: The Sponsors will commission independent bat experts to undertake regular and detailed collision victim survey visits for at least the first three years of operation, using internationally acceptable methods. A decision as to whether additional monitoring is warranted will be undertaken at the end of this period. If adverse impacts on any endangered or vulnerable species are identified, the Sponsors will take appropriate measures to reduce or eliminate such impacts (e.g. by modifying turbine cut-in speeds and/or turning off problem turbines during migration periods). Should offset measures be required, the Sponsors will prepare a Biodiversity Action Plan according to PS 6 requirements.	07/31/2014 12:00:00 AM	Completed	Completed	07/31/2014 12:00:00 AM