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.

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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

PS4 Community Health, Safety and Security - Local communities are sufficiently distant such that their health and safety will not be significantly impacted by either construction or operational activities.

PS 5 Land Acquisition and Involuntary Resettlement - There will be no physical or economic displacement related to this project and all land acquisition / leasing has been secured through “willing buyer-willing seller” arrangements.

PS7 Indigenous Peoples - Performance Standard 7 is not applicable as there are no indigenous peoples residing in the project area.

PS8 Cultural Heritage - PS8 is not applicable, since there are no significant cultural heritage features within the site. Notwithstanding, the Company will implement terrain prospecting (i.e. archaeological reconnaissance) during construction work and will implement a chance find procedure to deal with unanticipated impacts on cultural heritage that may be apparent on site. In the event of discovering archaeological remains, the relevant Authority will be notified and the presence of qualified professionals will be provided on the site, in accordance with regulatory provisions.

The proposed investment in the Project is a Category B project because of a limited number of specific environmental and social impacts posed by the rural location, and these can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Potential impacts from construction activities besides being mitigable are likely to be limited to project site; short term; and likely to have limited impact on environmentally sensitive areas. Further, it is possible to design and implement engineering and management measures to mitigate adverse impacts during construction and operation. And finally, although present, sensitive avifauna can be protected through acceptable and widely applied measures.

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.

Environmental and Social Assessment and Management System



The 2012 Spatial Plan for Alibunar recognizes that the region has significant wind energy potential and makes provision for the preparation of EIAs for sites with more than 10 MW generating capacity. The Spatial Plan emphasizes wind energy development potential as one of the major economic /land use activities for the region, and there are at least 7 other wind farm proposals in the area immediately surrounding the Alibunar site:



Malibunar WPP: adjacent and immediately to the east of the Alibunar site, 8 MW Electrawinds (Serbia) proposal

Kovacica (Blacksmith) WPP: 13 km to the west, 120 MW Electrawinds (Serbia) proposal

Plandiste WPP: 20 km to the north, 102 MW Energowind proposal

Alibunar 1 WPP: 2.5 Km to the north, 172 MW Windvision proposal

Cibuk WPP:10.5 km to the south, 142 MW CWP proposal

Kosava WPP: 18.5 km to the southeast, 142 MW MK Fintel proposal



All of the above are in design stage and there are no active wind farms in Serbia.



The sponsor has commissioned local consultants to develop an EIA under Serbian regulations which has been submitted for approval. The sponsor’s EIA has been informed by substantial bird and bat monitoring (undertaken over a period of 1 year between September 2010 and September 2011) and the scope of the EIA was informed by state agencies (including the Provincial Institute for Nature Conservation).



Site selection considered a number of alternatives and was guided by (i) the availability of consistent wind, (ii) avoidance of protected areas and natural habitat, as well as avoidance of proximity to built up areas/ habitation, and (iii) readily available access to existing transmission lines and transport infrastructure. The site comprises intensively farmed land and much of the surrounding landscape is also intensively farmed.



Electrawinds is completing a Supplemental Analysis to ensure project compliance with IFC Performance Standards. Additional mitigation and monitoring measures that are required will be defined in an Environmental Management and Mitigation Plan (EMMP) as part of this report. The EMMP and terms outlined in the Serbian environmental approval will, upon implementation of the EMMP and specific additional measures described below, comply with the IFC Performance Standards on Social and Environmental Sustainability.



Finally, the Company is conducting a Cumulative Impact Assessment (CIA) to assess cumulative impacts from the sponsor’s other wind farm prospects (Malibunar and Kovacica) and, to the extent possible, other wind farm proposals in the area. The CIA will have a specific focus on potential cumulative impacts to birds and bats, landscape and visual impact and noise, and the findings of the CIA will be incorporated in the EMMP.



Management and Monitoring Program

The sponsor has demonstrated capabilities to manage a range of environmental, social and occupational health and safety (OHS) issues at other a
ssets and via documents and systems that are in place in Electrawinds. The EMMP will detail how gaps in performance and management necessary to achieve compliance with IFC Performance Standards will be achieved. It will include details of mitigation and monitoring plans, communication and documentation and environmental commitments and training for contractors. The EMMP will be informed by company practices and experiences elsewhere, as well as the conclusions and recommendations of the Supplemental Analysis and CIA.



Relevant mitigation measures will be translated into environmental and social development requirements and made part of the contracts for construction activities as appropriate. Major mitigation measures for potential impacts that have been identified already are summarized under relevant PS sections below.



Organizational Capacity

Responsibility for implementation of EMMP will rest with the Alibunar Project manager (who will have overall responsibility for site development). Electrawinds will designate an E&S coordinator responsible for overseeing and monitoring the implementation of the Alibunar EMMP (including requirements and specifications relevant to contractors), as well as a dedicated on site Environmental Health and Safety (EHS) manager at the project site during the construction phase.



Electrawinds will also coordinate with relevant government departments and other stakeholders on matters related to the EHS aspects of the wind farm construction. The contractors’ EHS Managers will assume the main responsibility for EHS and social matters pertaining to their works (i.e. will be responsible for the implementation of the EMMP during construction works), as well as communication with, and the training of their respective construction crews in all aspects of the EMMP.



Environmental and social trainings will help to ensure that the requirements of the EMMP are clearly understood and followed by all project personnel (including contractors) throughout the project period. The primary responsibility for providing training to all project personnel will be that of the Alibunar E&S staff. The scope of the trainings (which will include “toolbox” training sessions for contractors) will cover general environmental awareness and the requirements of the EMMP, including:



(i) general environmental, OHS and socio-economic awareness;

(ii) waste management and disposal;

(ii) site safety and OHS requirements;

(iv) mitigation measures that are applicable to the project;



During the operational phase of the project, these trainings will continue to be conducted by the company as needed.



An Independent Ornithological Expert will be recruited to monitor the project for a period of two years once construction is complete to ensure that mitigation measures are being implemented and are proving effective (and to adjust these as necessary).

Electrawinds will establish a written Human Resources (HR) policy for the Group that will be applied to the Alibunar project and will actively disclose this Policy to staff (both employee and non-employee workers). The HR policy and procedures will be in line with Serbian Labor Law and IFC Performance Standard 2. It will specifically outline requirements in relation to contracts and terms of employment, working hours and overtime, training, leave, retirement, employee welfare, disciplinary action, health and safety, and wages and benefits, the principle of equal opportunity, fair treatment and non-discrimination and a grievance mechanism.



It is estimated that between 40-50 people will be on site during construction (including locally hired laborers who will manage road construction and site maintenance). On site contractors will include a main construction contractor (with responsibilities for roads, infrastructure etc), as well as specialist contractors (with responsibilities for turbine installation and mechanical /electrical works). Construction sub contractors will be responsible for an EHS induction program prior to starting work, a work-site orientation and on-the-job or formal training prior to being assigned a job.



Electrawinds has a successful track record in OHS at other wind farm sites it has developed, and will apply similar procedures and standards at the Alibunar project. This includes training and management of contractors OHS capacity and the implementation of a range of OHS requirements (relating to traffic and transport, handling of heavy and/ or dangerous materials, safety around electrical equipment, working at height, the provision of personal protective equipment, scaffolding and fall netting). Similar control and reporting measures will be put in place at the Alibunar site, and will be described in the EMMP.



During the operational phase of the project, management of EHS and social development aspects will become a routine function of the operational activities.

Construction phase impacts



A 8-10 month construction phase is envisaged, comprising the installation of road infrastructure, tower and turbine facilities, associated on site underground cabling, and storage / materials handling facilities. It is not anticipated that there will be any night time construction works or the need for on-site accommodation (except for site works facilities and sanitation).



Construction roads and surfacing will involve earth moving and the development of surfaced features which will necessitate the delivery of gravel and other construction materials to the site. To the extent possible roads will be formed from sub soil and clay obtained on site.



Electrawinds will develop Working Site Regulations in more detail nearer the construction period and specific EHS requirements to comply with Serbian and IFC requirements will be part of all contracts, and will also be part of the general site Health and Safety (H&S) plan, imposed by the official Serbian H&S coordinator for the site. These will be defined in the EMMP.



Road construction and expansion, and construction works associated with turbine foundations and the substation will require proper drainage and erosion management; for this, specific contractor actions and responsibilities will be set out in the EMMP. Any land that will be disturbed and excavated during construction will be re-contoured and returned to its original use where possible. Compensation arrangements for damage to crops during construction have been established by the company.



General waste will be managed in accordance with Working Site Regulations and a site waste management plan will be developed with attention to waste reuse and recycling opportunities. Non-recyclable solid waste will be sorted and separated in appropriate leak proof containers for eventual disposal within regulated Municipality facilities at Alibunar. Excavation and construction waste will be reused on site where possible. Hazardous waste will be separated and appropriately labeled and stored in leak proof containers. Liquid hazardous waste (oils, fuel, chemicals) will be stored in metal/plastic drums in concrete bunded areas. Transportation and disposal of hazardous waste will be undertaken by licensed companies with trained employees equipped with appropriate vehicles and equipment.



Fuel storage on site will be designated to the Contractor and a management plan will be imposed through the Working Site Regulations. Any spills will be monitored and controlled and a spill control plan will be implemented.



Diesel generators will be used for power to operate construction equipment and for any other on-site requirements (such as welding and works lighting). Emissions from the generators will be minimized by ensuring that the engines are always properly tuned and maintained.



Dust may be problematic during dry and windy periods and Electrawinds will implement dust suppression and watering techniques to mitigate
risks to drivers on the A70 and impacts to adjacent crops.



The distance to local communities (a minimum of 2.5Km) means that construction noise impacts will not be significant, neither should construction traffic create significant additional traffic disturbance (given the heavy use of the existing A70 trunk road). Nevertheless a traffic management plan will be implemented to address large vehicle movements necessary to deliver turbine, blade and tower materials, and wheel washing will be implemented to reduce the risk of mud and soil from the site contaminating the A70. Turbines, towers and blades will be transported on major roads from the port at Pancevo to the project site (approximately 100 vehicle movements are anticipated to bring materials to the site). Traffic disturbance will be mitigated by night time transport, route planning and management, and traffic management signage. All measures to be developed in cooperation with provincial/ regional authorities and regulations.



Specific measures will be designed for contractor management, with a focus on truck fleet maintenance, cleaning/washing of ready-mix concrete trucks, cleaning of tires prior to entering the A70 road. Electrawinds will inform all local communities about this plan and make the plan available locally.



Vehicles and construction machinery will 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 use of Personal Protective Equipment.



Operational Phase Impacts



Operation and maintenance activities will be limited, and will include normal periodic maintenance and site security management. There will be limited traffic accessing the site and no residential staff at the farm. Key potential operational impacts include potentially negative noise and visual impacts, and positive impacts related to the reduction of green house gas emissions



The project EIA assessed potential noise impacts and determined that the distance to local communities precluded significant risk of noise disturbance and that the site would operate in concordance with Serbian regulations (the maximal permissible limit of noise is 35 dB(A) at night and 40 dB(A) during the day outside public facilities).



The turbines and towers will be visible from the A70 trunk road and to some extent from Vladimirovac and Alibunar. At greater distances, the impact of the turbines on visual amenity at the landscape level reduces to negligible or no effect. Due to the fact that the local populations are remote from the Project site no impact or risks to the health and safety of the general public are expected from a malfunction of turbines such as blade or ice throw. Shadow flicker/blade glint impact will be negligible since shadow flicker will be directed north of the A70 and blade glint will be dulled within a few mo
nths of operation.



Annual production from the 21 turbines is estimated at 132 GWh and the annual GHG reduction is predicted to be 124.7 tCO2 per year.

Wind farms can impact biodiversity (principally birds and bats) through displacement of species due to loss of suitable feeding and/or breeding/wintering habitat as a consequence of direct loss of habitat to physical plant and assets; bird or bat collision with turbine blades; disturbance within and around the turbine envelope; and creation of a barrier to dispersal, regular movements or migration.

Electrawinds has sought to reduce potential impacts to biodiversity through the development of the project on land that has little value to birds or bats (for nesting, foraging, roosting or other activities), and through siting the farm away from protected areas such as the Deliblato Sands (Deliblatska Pescara) and other habitats that are important to birds, bats and other biodiversity. The project site has no natural habitat connectivity with Deliblato Sands and ecological survey work undertaken for the EIA did not indicate that birds or bats were traversing the land between Deliblato Sands and the project.

The site does not contain natural habitats or features that would attract large numbers of birds (wetlands, rough grazing etc), neither are there any bat roosts on the site, though the northern parts of the site (adjacent to the Volovski Put) are of medium importance to bats for hunting and as use as flight corridors. There is a risk that birds and bats may be killed or injured by turbine blades, and that the wind farm (and other farms that may be developed) could create a barrier to the movement of both birds and bats.

A detailed and substantial assessment of potential impacts to birds and bats undertaken over a year long period (September 2010 and September 2011) informed the EIA. From this study it is evident that a range of protected, endangered and threatened bird and bat species were present within or near the site, and which would be at risk if the wind farm was developed. These include Stork (Ciconia ciconia), March harrier (Circus aeriginosus), Hen harrier (Circus cyaneus), Montagu’s harrier (Circus pygarus), Red-backed shrike (Lanius colluro), Common noctule bat (Nyctalus noctula), Serotine bat (Eptesicus sertinus), Kuhl’s pipistrelle (Pipistrellus kuhlli), Daubenton’s bat (Myotis daubenonii). The EIA concluded that the choice of the location is ecologically, economically and spatially viable, sustainable and acceptable for wind farm development, but that special protection measures need to be developed to mitigate risks to birds and bats.

To ensure that the project is developed in compliance with IFCs Performance Standards and potential cumulative effects from a number of wind farms over a limited area, Electrawinds has commissioned additional work that will address the following aspects: likely impacts to birds and bats (and specifically vulnerable, threatened or endangered species); how these impacts can best be mitigated through the application of the mitigation hierarchy (to avoid impacts, reduce, restore / remediate and offset); what cumulative impacts might be evident as a result of multiple wind farms being developed adjacent and near to the Alibunar site. The conclusions of this study (such as site management, operational, and habitat management requirements including, if needed, an operational mode providing a temporarily shutdown to ensure no significant impact on species in question) will be used to inform the EMMP. An Independent Ornithological Expert will be recruited to monitor the project for a period of two years once construction is complete to ensure that mitigation measures are being implemented and are proving effective (and to adjust these as appropriate). Data from ongoing monitoring will be provided to the Provincial Institute for Nature Conservation to inform wider wind farm planning and development.

Stakeholder engagement has been an integral part of the EIA process to address the key concerns of surrounding communities over the past years. The sponsor has engaged in extensive consultation in both communities including public meetings with Regulatory Agencies (Utilities and Ministries), meetings with Municipality Officials, consulting with the Bird Protection and Study Society of Serbia and SEWEA (Serbian Wind Energy Association), presentations of the project at regional conferences, publishing ads and announcements in local and regional newspapers in different languages (Slovak, Hungarian, Romanian and Serbian).
Meetings with Alibunar Municipality authorities (the Mayor, Vice President Office, and Office for Urbanism and Cadastre Office) were held on a weekly basis since the beginning of the project development in 2010. During the planning phases the meetings with Regulatory Agencies (Provincial Secretariat for Planning, Construction and Environment Protection, Public Utilities Co, Ministries…etc) were held on a regular basis and when needed to obtain conditions and opinions regarding planning procedure for the construction of “Alibunar” wind farm. Meeting with the Bird Protection and Study Society of Serbia was held in 2012. A number of presentations about the project were delivered at different national and international events i.e. 6th International Renewable Energy Forum Serbian Energy Challenge October 25, 2012; Association of Energy Sector Specialists March 27, 2012; South-East Europe Grid Codes Comparison (Serbia, Croatia, Montenegro, Bosnia and Herzegovina, Romania and Bulgaria) May 4, 2012; European Wind Energy Association, Wien 2012; Serbian Chamber of Commerce,2012; CEDEF (Central European Development Forum) 2012; SEWEA meeting were held at SEWEA office in Belgrade since 2010.

In addition the Company has successfully concluded 41 bilateral agreements with land owners on the site. This latter process included individual meetings with all landowners and their families (with legal representation), discussion of company needs and a subsequent return visit to discuss land owner interest in entering a commercial relationship to lease or sell land to the company.

Electrawinds is developing a Stakeholder Engagement Plan (SEP) that identifies key stakeholders and ongoing information and communications plans relating to the project. The SEP will be reviewed periodically during implementation and will be updated as necessary to ensure effective ongoing engagement with local communities. Public announcements through newspapers, radio and other appropriate channels will be used to inform affected communities of construction and operational issues and will be part of the SEP.

The SEP will include a grievance redress mechanism (GRM) to address concerns that the communities living in the vicinity of the project may have. The main objective of the GRM will be to provide a mechanism to mediate concerns. It will also facilitate a public forum to raise objections and through mediation, to address these issues adequately.

Electrawinds (Serbia) will make available the original EIA, Supplemental Analysis, EMMP and SEP to stakeholders well before the commencement of construction. This will ensure that the local communities are brought up to date and made aware of the project, its key impacts, the mitigation measures and the implementation mechanism.

The following documents are disclosed as attachment to this ESRS:
Environmental Impact Study
Bird and Bat Impact Study
Environmental Social Action Plan
The Company will also locally disclose the above listed documents as well as the Supplemental Analysis, the Stakeholder Engagement Plan and EMMP, at the Company’s offices in Belgrade and Site office in Alibunar.
Any queries and/or comments about the Project may be directed to:

Alexander Vulovic
Vladimira Popovica 8,
Office 811 | 11070 New Belgrade
Tel +381 11 7853 705
Fax +381 11 31 222 57
Mob +381 62 471 064
mailto:alexander.vulovic@electrawinds.be

Broad Community Support is not applicable for this project

	Action	Completion Schedule
	Assessment and Management of Environmental and Social Risks and Impacts
1	Develop Environmental Management and Mitigation Plan for Electrawinds Serbia Alibunar Project comprising full details of environmental, health and safety and social performance requirements and obligations for the operation of the Alibunar project (including requirements for O&M contractor, EIA Approval, Gap Analysis, and Cumulative Impact Assessment) and including detailed timelines for implementation of specific mitigation measures and monitoring activities.	End of 2Q 2014
	* - ESAP may be modified to cover EHS issues that may be identified during the project implementation.