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 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
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

The project is located 28 km upstream from the Mangla Reservoir within the Poonch river which is heavily impacted by human activity. However, the section of the Poonch river where the project is located has been recently declared a National Park by the local environmental authorities due to the presence of the Kashmir Catfish (Glyptothorax kashmirensis) and Mahseer (Tor putitora), respectively listed as Critically Endangered (CR) and Endangered (EN) in the IUCN Red List. Therefore, according to IFC’s Performance Standard 6 on Biodiversity Conservation and Sustainable Management of Living Natural Resources, the project is located in a Critical Habitat. According to IFC’s Policy on Environmental and Social Sustainability, Gulpur is a Category A project because it may cause significant adverse impacts on Critical Habitat that may be diverse and irreversible.
There are no Indigenous Peoples in the project area, and therefore PS7 is not considered applicable. There are no cultural heritage impacts anticipated, hence PS 8 is also not considered applicable.

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: In September 2013, an Environmental and Social Impact Assessment was completed. This ESIA referred to the project as originally conceived; it involved a smaller dam of 45 meters high located further upstream on the ridge, leading to large reservoir of 22 million m3, and a flooded area of 3.6 km2 potentially displacing 115 households (over 700 people), and a dewatered river reach of 6.1 kilometers from the dam to the powerhouse. After an exhaustive alternatives analysis that involved environmental, social, technical, and financial considerations, the company decided on the current Gulpur HPP design. This new designed resulted on a project with the same generation capacity, a taller dam and a deeper reservoir of 42 million m3, but with significantly less environmental and social impacts, including minimal need for involuntary resettlement of people.

Once the new design had been agreed upon, Hagler Bailly Pakistan updated the Environmental and Social Impact Assessment (2014 ESIA). The ToRs for this updated ESIA were prepared by the client in consultation with the IFC and other lenders. This ESIA updated in 2014 is aligned with good international industry practices and commensurate with what would be expected for a project of this nature, and included, but was not limited to: (i) collection of additional social and environmental baseline, (ii) a comprehensive downstream release / ecological flow assessment, (iii) a Critical Habitat Assessment (CHA), (iv) a Cumulative Impact Assessment (CIA), (v) climate risk assessment, and (vi) land acquisition, livelihood restoration and involuntary resettlement plan (LARP). All these assessment are included within the ESIA or are stand-alone studies which are disclosed together with this review summary.

Gulpur’s potential direct impacts include: (a) conversion of aquatic and riparian habitat as a result of the modification of the hydrological regime of the Poonch river, both upstream from the dam before its confluence with the Ban Nullah tributary by creating a reservoir, and in the 700-m long dewatered segment from the dam to the power house where the natural flow regime will be significantly lowered; downstream from the tailrace the flow will be restored to its natural regime; (b) barrier effect to fish and invertebrates caused by the dam; (c) limited impacts on forest and vegetation cover; (d) permanent acquisition of 93.18 Acres (37.7 ha) of private land resulting in the physical displacement of 4 households (26 people), and the economic displacement of a total of 76 households; (e) potential safety risks to affected communities; and (f) a number of short-term disturbances typical of any new construction and civil works (e.g. air and noise emissions, wastewater, solid and hazardous waste generation and disposal, workers’ occupational health and safety risks, among others).

Cumulative Impacts: Gulpur HPP is the first of a series of proposed hydropower project in the
Poonch river. Once it is successful implemented, it is likely to send a positive signal to the other hydropower developers, which could potentially lead to cumulative impacts that if realized would completely convert the Poonch river. A Strategic Environmental Assessment (SEA) prepared by the IUCN in 2014, states that the potential for hydropower development on the Jhelum and Neelum rivers is substantial, but recommended caution while developing hydropower in Poonch river due to its high environmental value and the relatively small contribution of hydropower development in the Poonch river could make to the national economy (about 470 MW). At the time of appraisal, local government had awarded 4 other hydro development licenses on the Poonch river. Upon IFC’s request, the company undertook a basin-level Cumulative Impacts Assessment (CIA) as an integral component of the updated ESIA. This assessment identified that the main potential cumulative impacts for cascading hydropower development in the Poonch river were related to sediment transport and impaired fish migration, and predicted severe impacts on fish populations if all five HPPs are constructed in the absence of basin-wide cumulative impact mitigation measures.

The ESIA proposes a series of mitigation measure to manage cumulative impacts. The most fundamental measures have been consolidated in a long-term Biodiversity Action Plan (BAP) that will be further discussed under PS6 and which draft is attached to this review summary. The ESIA highlights the potential Gulpur HPP has to become a benchmark of good environmental and social practices for all developers, and includes recommendations for collective action to address potential cumulative impacts and their implementation, such as (a) enhancing availability and sharing of basin-level environmental and social data to ensure consistency and uniform access to all developers; (b) coordination of actions to implement a basin-level integrated management plan to protect and develop catchment areas aimed at minimizing erosion and sedimentation and supporting ecosystem conservation; and (c) making efforts to share infrastructure whenever possible (e.g. access roads, transmission lines). In addition, the Department of Wildlife and Fisheries has given a conditional approval to Gulpur HPP stating that all future projects will have to abide by the “net gain” principle required for IFC’s financing, which is likely to place limitations on the development of future projects on the Poonch river. (see Appendix A of the attached draft BAP for a copy of the local authority resolution)

Management Program: As a result of the updated ESIA the company developed an Environmental and Social Management and Monitoring Plan (EMMP) which summarizes the organizational requirements, and management and monitoring plans to ensure that the necessary measures are taken to (a) avoid or mitigate potentially adverse effects, (b) maximize potential benefits, and (c) operate
in compliance with applicable local laws and regulations and IFC’s Performance Standards. The EMMP include a Construction Management Plan, Air Pollution Control Plan, Waste Management Plan, Muck Disposal Plan, Spill Prevention and Contingency Plan, Construction Labor Management Plan, Traffic Management Plan, Health and Safety Plan, and an Emergency Preparedness Plan. In addition, the EMMP also outlines a series of additional plans that need to be further developed by the client, such as the Biodiversity Action Plan (BAP, and advanced draft now completed and attached to this ESRS), Ecological Flow Management Plan, Sediment Mining Plan, Socioeconomic Management Plan, Land Acquisition, Livelihood Restoration and Involuntary Resettlement Plan (LARP, advanced draft now completed and attached to this ESRS), and a Corporate Social Responsibility (CSR) Plan. As discussed under PS6 below, and as a requirement for IFC’s financing, the BAP was prioritized and an advanced draft it is disclosed together with this review summary. A sustainable Sediment Mining Plan will be prepared to develop an understanding of sediment deposition patterns, and to devise a strategy for mining that minimizes impact on the river habitat. The Corporate Social Responsibility (CSR) Plan will provide detailed information on method, roles and responsibilities of interaction with the local community, mitigation of socio-cultural impacts, socio-cultural conflicts and enhancement of positive impacts. The proposed Socioeconomic Management Plan will include providing water supply and health care facilities, skills training, and capacity building activities, among others. Terms of Reference for these plans are included in the ESIA’s EMMP and presentation of these plans is both a local legal requirement and will be a requirement for IFC’s investment.

In order to ensure compliance of the EMMP and other plans, as part of the ESAP, MPL shall develop an overarching Environmental and Social Management System (ESMS) for the project. This ESMS will build on the company’s corporate ESHS policies and procedures and follow good international industry practices (GIIP) and be consistent with the requirements of IFC’s Performance Standard 1; as a minimum it shall include an ESHS Policy, proposed organizational structure, a procedure to identify of ESHS risks and impacts, management programs, an overarching monitoring, reporting and non-compliances tracking mechanism; and a stakeholder engagement plan.

The ESMS will be reviewed and approved by the client’s upper management and will be applicable to the EPC contractor / O&M provider and major sub-contractors. Towards achieving this goal, as also noted in the ESAP, the company shall assure that the EPC Contractor prepares a Construction Environmental and Social Management Plan (CMP) demonstrating the manner in which it will comply with the requirements of the EMMP. Furthermore, KOSEP (O&M) will be mobilized to the project site ten months prior to cons
truction completion to ensure smooth transition/taking-over and plant commissioning. Per the ESAP, prior to the commencement of operations, the company shall develop the operations environmental and social management plan, in form and content satisfactory to the IFC, conforming to good international industry practices such as those reflected in IFC’s PSs and World Bank Group applicable EHS Guidelines.

Organizational Structure, Monitoring Programs, and Reporting: At the corporate level, the company has a comprehensive ESHS Policy and procedures, organizational structure, and has a dedicated ESHS & CSR Manager for the project. The latter is in charge of customizing the corporate policies and procedure to the project, and managing and supervising project’s compliance with ESHS requirements and EMMP, as well as delivering training and preparing periodic ESHS compliance reports. In addition, all sponsor companies also have their own environmental, social, health and safety policies and responsible personnel. In total, there are 6 professionals with ESHS responsibility working on this project.

Regular monitoring of construction and commissioning activities will be undertaken against the environmental requirements as per relevant standards, specifications and EMMP. External experts will be engaged for ecological monitoring during the construction and operation phases of the project; key parameters that will be monitored will include fish abundance and diversity with special attention to the Mahaseer fish and Kashmir Catfish, macro-invertebrate communities, periphyton biomass, bankside vegetation, and Eurasian Otter population. In addition, river water quality, environmental releases from the dam, and changes in hydrology and geomorphology of the river due to project operation will also be monitored. The purpose of monitoring will be to assess the performance of the undertaken mitigation measures and to immediately formulate additional mitigation measures and/or modify the existing ones aimed at meeting the environmental compliance as appropriate during construction and operations. ESHS compliance reports will be prepared periodically and distributed to the company’s upper management as well as the IFC and other lenders.

Human Resources: MPL has a comprehensive Human Resources (HR) policy and procedures that are consistent with the requirements of Pakistan’s labor laws and IFC’s PS2. The HR policy will be provided to all employees at the time of their induction, detailing terms of employment, wage and benefit scales, among other relevant information, including a clear statement regarding employees’ freedom of association and collective bargain and commitment not to engage in any form of forced or child labor.

The project will employ about 700 skilled, semi-skilled and unskilled workers for construction. The company will use best efforts to hire the majority of unskilled labor and, to the extent possible semi-skilled and skilled workers from the local area. While most of the locally-hired workforce will likely go back home on a daily basis, the remainder will be accommodated in the labor camps. It is expected that approximately 400 people will be housed in construction camps for four years during construction. No significant numbers of migrant workers are expected. Per the ESAP, the company will adhere to IFC’s Worker’s Accommodation guidelineshttp://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustainability/publications/publications_gpn_workers accommodation

for construction to be outlined in the Construction Management Plan. As part of the ESAP, the EPC Contractor will implement worker camp standards and regulations, including provision of adequate accommodation facilities in all its campsites in accordance with internationally recognized standards (i.e. space standards for dormitories, minimum quantities of sanitary installations, maximum distances to installations, resting area requirements at construction fronts, among other key issues) and defining the code of conduct for workers. Owing to the hilly terrain, there are limitations in the availability of suitable areas near the project structures for establishing residences, workshops, batching plants and material storage areas. Therefore, it is possible that the company may establish workers accommodation in Kotli City and provide transportation to site.

During operations, it is expected that approximately 100-120 people will be employed.

Occupational Health and Safety (OHS): As outlined in the EMMP, OHS risks and management procedures will be included in the Construction Management Plan. As identified in ESAP, this plan will ensure that the EPC contractor / O&M provider develop a site-specific over-arching OHS procedure for the construction and operations phases of the project as a whole. The procedure will identify task-specific OHS risks, define safety protocols to follow for each task, personnel qualification, limitations and equipment needs (e.g. personal protective equipment), and training programs. The company will also ensure that the EPC contractor / O&M provider track OHS performance during both construction and operations. The E&S Manager will record and tr
ack any OHS incidents through an incident tracker and will report on incidence and severity rates during both construction and operations.

Climate Change / GHG: This is a renewable energy project, which is expected to have a net positive impact by offsetting energy sourced from fossil fuel power projects. A climate change study was conducted to evaluate climate change impacts on issues that are relevant to the operation of the hydropower plant. This study included an initial risk screening, analysis of downscaled Global Climate Models (GCM) results, analysis of hydrological changes, estimates of reservoir sedimentation, projected climate change impacts on water supply, greenhouse gas (GHG) emissions from the Gulpur HPP reservoir, and evaluation of disease risks. Results of the study showed that evaporation changes in the Gulpur HPP basin may occur as a result of climate change, even in the absence of irrigation demand. It also indicated that the amount of GHG emissions released from the reservoir changes over time due to a variety of factors that include climate, water flow through the reservoir, and decomposition (i.e., carbon content) of the submerged biological matter. Of the studies presented, the range of annual emissions of a HPP similar in size and location to the Gulpur HPP could be between 1,407 tons and 27 million tons; however based on terrain, dry weather, sparse vegetation and consequently limited organic matter to be flooded it is likely that reservoir’s GHG emissions will fall on the lower end of the spectrum and, and will be outweighed from the carbon reduction emissions generated, which are estimated to be 240,149 tons per annum tCO2-eq/year. As part of the ESAP, the company has committed to develop a GHG Protocol for assessment of the GHG emissions from the reservoir once the HPP is operational.

Pollution Prevention and Control: Construction activities will include excavation, blasting, drilling, quarrying and burrowing, aggregate crushing, concrete batching, muck disposal, concrete laying, brickwork, cabling, erection of structures and equipment. The sections that follow describe principal measures included in the EMMP to address impacts from these activities.

Air pollution: The ESIA indicates that there are no major sources of air pollution, i.e., no industries in the project’s air-shed. Measured concentrations of carbon monoxide, nitrogen dioxide, sulfur dioxide and particulate matter PM10 in ambient air were found to be within National Environmental Quality Standards (NEQS). The ESIA also indicates that dust impacts on air quality during construction are deemed to be moderate. A batching plant on site will contribute to dust emissions in the area. Vehicle and machinery exhaust emissions will also affect air quality with potential impacts on the surrounding community. The EMMP includes measures to mitigate atmospheric pollution, based mainly on regular sprinkling unpaved roads and work areas, and systematic maintenance of construction vehicles and equipment.

Noise: During construction activities for the project, particularly drilling, blasting, excavation,
generators and operation of batching plant, noise levels are expected to increase in the area. Noise control measures will be adopted by the EPC contractor to make sure that noise levels are kept close to existing background. It is expected that the noise impact will be limited and not be beyond 200 meters from construction site, construction will be performed only during day time, and traffic will be managed to avoid congestion on the public roads.

Waste: The potential impact from domestic solid and wastewater disposal is significant as it is expected that approximately 400 people will be deployed on the construction site for approximately four years. An assessment on the impact of the physical environment was carried out under the ESIA. Waste such as sewage, wastewater, construction waste, chemical waste and other solid waste pose a risk in the area if not disposed of carefully. The main surface water resource of the project area is the Poonch river, which flows along Kotli-Mirpur Road and drains into Mangla reservoir. Water quality of the river is generally fair and it is used for recreation, washing, and other non-consumptive purposes (e.g. illegal mining, mills). However, since the river water is contaminated from the disposal of sewage from towns, villages and settlements along the river, the Poonch river water is not used for human consumption or irrigation. The main source of drinking water in the area is ground water and springs. Groundwater drawdown impacts are not expected as there is no inhabitants on the ridge through which tunneling will be drilled, and the settlements closest to the dam construction are located more than 500 m away from the area where major excavation activities will take place. Measures included in the EMMP to manage waste-related impacts include control of soil erosion, treatment of wastewater from camp and office facilities, and proper collection, storage and disposal of solid waste. Depending upon the quality of the excavated material, some of the excavated material will be used to meet the requirement of aggregate rock fill at cofferdams and stone pitching. Surplus excavated material will be deposited in a designated spoil area at the project site and slope stabilization measures will be adopted.

Community Health and Safety: The local community, especially women and children, suffer from water borne diseases including diarrhea. Of the three diseases in Pakistan addressed in the ESIA, it is noted that the projected temperature and precipitation pattern changes as a result of global climate change could increase the future risk of malaria, dengue fever and Crimean-Congo hemorrhagic fever (CCHF) in the project’s area of influence. The EMMP proposes to provide potable water by constructing small-scale drinking water supply systems or installing hand-pumps at certain convenient points in the potentially affected urban and rural communities including Rehmani Mohalla and Naroch Colony located in the vicinity of the project site. Provision of clean drinking water to communities will contribute to improve the general health of women and children, save families from extra efforts / fatigue and reduce water buying costs. The EMMP outlines that the CSR Plan will allow access of local communities to the health infrastructure constructed for project workers, as well as provide health care services to the local community (e.g. polio vaccination, dispensary facilities, and local clinics).

Dam Safety: Saman Engineering was hired as external expert with relevant and recognized experience in similar project - and different from those responsible for the Gulpur HPP’s design and construction- to perform a Dam Break Analysis Report. This report provides risk and hazard classification in the case of dam failure. The results of a dam break study include the extent of the areas impacted as the flood wave progresses. In the case of dam breach, downstream areas will be inundated with potential damage to bridges, houses, and cultivated lands. The EMMP discusses details for provisions to account for dam break analysis and on-going monitoring. As noted in the ESAP, the company will develop a detailed Emergency Response Procedure (ERP) including detailed emergency response in the cases of dam breaks, natural disasters, earthquakes, fire / explosion, severe traffic accidents, violence and/or social unrest, hazardous products spills, floods, landslides, fall of people into water channels, and forest fires.

Road Traffic: The ESIA includes an assessment of impacts on traffic during the construction of the project on two junctions, Gulpur and Palak, and was seen to have low traffic volume, and well below the recommended usage limits. Currently the roads can cater for the needs of the traffic but with the anticipated increase due to the project, there are likely to be impacts on the existing road infrastructure. The EPC contractor will be responsible to upgrade and maintain existing roads and develop a new 650 meter access road to connect the project facilities to the main road. Negative impacts on ecology from road construction as well as increased traffic on the newly constructed road are expected to be minimal. Mitigation measures are outlined in the EMMP to includ
e size of trucks and vehicle in specific access routes, place of parking of machinery and vehicles, paving of access routes and paths, among others.

Security: Preliminary information obtained during appraisal is that Gulpur HPP will hire a government-certified private security company to manage security, in addition to implementing standard site security arrangements such as a perimeter fence, controlled access, and road checkpoints. This licensed security provider will supply armed guards trained in the use of weapons and appropriate and proportionate use of force. Government security may also be provided to maintain the security of project area as a whole. Given the potentially volatile security situation in this region, as part of the ESAP, the project company will follow key elements of PS 4. The company will perform a Security Risk Assessment (SRA) with a qualified international security risks firm and will present a Security Management Plan (SMP) to assure that employees, sub-contractors, as well as physical assets are safe, under surveillance, and in a controlled environment. The SMP will be (a) site specific and comprehensive (b) commensurate to the security risks, (c) describe security risks and detailed response procedures, (d) aligned with the Voluntary Principles on Security and Human Rights (http://www.voluntaryprinciples.org), and (e) assure that all security personnel, but especially those who will bear arms, are trained and operate consistently with such principles. This plan will also include an initial awareness workshop and site briefing for all employees. The SRA will also identify any potential risks that its own and/or government-owned security arrangements may pose to those within and outside the project site, including the residents of the nearest towns. As a general rule, the company’s security response will be guided by principles of proportionality, avoidance of confrontation, use of a preventive and defensive approach commensurate to the nature and extent of the threat, and respect for human life and basic human rights. The company will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force and fire arms, and will impose a Code of Conduct toward workers and nearby communities. The project company will use best efforts to ensure that Government security personnel act in a manner consistent with these principles.

The Poonch River is a warm water river and the water temperature approaches almost 30oC during the summer months. A total of 37 fish species have been recorded from the Poonch river. Six fish species observed in the study area are listed on the global IUCN Red List of Threatened Species. The Kashmir Catfish (Glyptothorax kashmirensis) is listed as Critically Endangered (CR), the Mahseer (Tor putitora) is listed as Endangered (EN) while the Common Carp (Cyprinus carpio) and Twin-banded Loach (Botia rostrata) are listed as Vulnerable (VU). Moreover, Pabdah Catfish (Ompok pabda) and Butter Catfish (Ompok bimaculatus) are listed as Near Threatened (NT). Other important endemic fish species found in the project’s area include Pakistani Baril (Barilius pakistanicus), Punjab Loach (Schistura punjabensis) and Nazir‟s Catfish (Glyptothorax naziri).

Critical Habitat: Due to its high fish diversity and importance in supporting fish of both conservation and economic importance, in December 2010, the Poonch river along with its tributaries was declared as Poonch River Mahaseer National Park by local environmental authorities. The nomination of this National Park has been promoted and/or endorsed by a number of reputable environmental NGO, including but not limited to IUCN, WWF, Himalayan Wildlife Foundation, and Snow Leopard Foundation, as they argue that the Poonch river is essential for the global survival of Kashmir Catfish, and presents a unique natural abundance of the Mahaseer fish, an endangered species whose population has been consistently declining all over Himalayan rivers.

Upon IFC’s request, and as an integral component of the ESIA, a Critical Habitat Assessment (CHA) was conducted. This assessment confirmed that the project will be sited in a Critical Habitat, and therefore the project company will developed a Biodiversity Action Plan (BAP), of which an advanced draft is disclosed together with this review summary.

The Project ESIA evaluated various scenarios to address both flow and non-flow related pressures on the biodiversity of the Poonch River. See below for discussion of flow related pressures. The non-flow related pressures include selective fishing (with nets and rods), non-selective fishing (with gill nets, poisons and dynamite), sediment mining (sand, gravel and boulders), nutrient enrichment (waste water from human population centers), and harvesting of riparian vegetation for building materials. The ESIA scenarios predict that under a “business as usual” (BAU) scenario, even without the Gulpur HPP, the non-flow related pressures on the aquatic ecosystem will double in intensity over the next fifty years, predictably resulting in significant decline in abundance and diversity of the aquatic and semi-aquatic flora and fauna. The ESIA proposes a scenario (Pro 2 Scenario) that includes actions (proposed in the BAP) to reduce 2013 levels of these pressures by 50%, which is predicted to achieve net gain of aquatic biodiversity in th
e project area. For the two fish species that trigger Critical Habitat (Mahaseer and Kashmir Catfish), the ESIA “business as usual” (BAU) scenario – i.e. even in the absence of the Gulpur HPP - predicts extreme losses (46 - 100% loss) relative to 2013 levels over the next 50 years without any preventive actions. The ESIA Pro 2 scenario, with the BAP actions, predicts an overall net gain for both fish species.

Ecological Flow: Hagler Bailly Pakistan appointed Southern Waters to assist with an environmental flow (EFlow) assessment for the Poonch river in the proposed Gulpur HPP’s area of influence. The objectives of the assessment were (a) to evaluate present day condition (i.e. the present structure and functioning) of the Poonch river from upstream of Gulpur HPP to Mangla Dam; and (b) to evaluate how the condition of the river would change under different operational scenarios for the proposed Gulpur HPP, including a non-project business-as-usual (BAU) scenario. Hydrological data collected during the last 50 years, shows that in the project area the Poonch river has an average mean flow of approximately 110 m3/s, with 5-day high and low flows of 726 m3/s and 17 m3/s, respectively. Downstream Response to Imposed Flow Transformations (DRIFT - http://www.southernwaters.co.za/downloads/drift.pdf) methodology was used to assess impact of varying levels of downstream releases / environmental flow on project economics and aquatic ecosystem integrity. To finally select an EFlow regime that achieves a balance between ecosystem integrity and project financial viability, the company discussed these modelled impacts with key stakeholders, including environmental authorities and representatives from the environmental NGOs that promoted the Poonch River Mahaseer National Park nomination. Given the limited length of the dewatered section from the dam to the power house tailrace of only 700 meters and the company’s commitment to a true run-of-river operation (e.g. non-peaking), the study determined that the optimal trade-off was at 4 m3/s, and that beyond this release, there was limited-to-nil ecological gains by increasing Eflow at the expense of power generation. Prior to plan commissioning, as a requirement to IFC financing, Gulpur HPP will complete a comprehensive Ecological Flow Management Plan, consistent with good international industry practices and PS6 requirements.

Terrestrial and riparian Natural Habitat: Site clearance and construction of project infrastructure will result in immediate and direct modification of land and a loss of terrestrial habitat leading to loss of plants and animals in the project’s influence area, including the area to be flooded by the new reservoir. The area of habitat loss consists largely of riparian habitat and scrub forest. No threatened flora or fauna species were found or reported from this area. Limited signs of the Otter (Lutra lutra, listed as Near Threatened in the IUCN Red List) were observed, and this species is
known to be present in similar habitat. No critical habitat, threatened or unique ecosystems were identified in the terrestrial and riparian impact area. The decrease in biodiversity and ecological function caused by construction related disturbances is predicted to be minor. Mitigation measures include following the measures outlined in the Construction Management Plan, such as development of a reforestation program, and prohibition of hunting, poaching and/or logging by the workforce.

Biodiversity Action Plan (BAP): A comprehensive BAP will be developed, outlining Pro2 scenario commitments to achieve net positive gain in the ecological values that triggered Critical Habitat classification, namely (a) Kashmir Catfish, (b) Mahaseer fish and (c) Poonch River Mahaseer National Park conservation objectives.

These actions will include, among others: (i) implementing an effective watch and ward system supported by institutional arrangements to reduce illegal and indiscriminate hunting and killing of wildlife (both aquatic and terrestrial) including several bans on non-selective fishing, fishing in tributary breeding grounds, fishing during the breeding season, and sediment mining in ecologically sensitive areas; (ii) prohibiting removal of vegetation that is important for supporting biodiversity; (iii) increasing park staff, patrols and mining inspectors; (iv) limiting areas designated for sediment mining; (v) banning of livestock grazing and wood collection in sensitive areas; and (vi) conducting environmental awareness workshops for local communities. The Sponsors will finance supplemental park staff, equipment, facilities, and logistics to close the existing capacity gaps – including the construction of two park management offices and support to the local Fish and Wildlife Department (FWD) on the construction of a hatchery for Mahaseer on the Poonch river. This hatchery is a key component of the actions needed to increase numbers of the Mahaseer in the downstream portion of the Poonch river after the dam is in place as they will be cut off from their breeding grounds upstream. Therefore, success of this hatchery is critical to the success of the BAP actions and will be planned and monitored carefully. In addition, project sponsors will provide technical support to the local FWD by engaging experts in park management and river ecology.

Institutional arrangements proposed in the BAP consists of (vii) putting in place a protection system for Poonch River Mahaseer National Park partly financed by the project and implemented by an independent organization; (viii) active support from the local FWD by making available existing staff for protection and assistance in coordination with other government line departments such as police and district administration; (ix) commitment by the local FWD to provide legal authority to the staff of the independent organization for exercising powers under wildlife legislation; (x) oversight and monitoring by the Wi
ldlife Management Board of the local FWD; and (xi) monitoring by an independent third party on a long term basis.

These actions, along with development of a strong Poonch River Mahaseer National Park management plan, are expected to lead to net gain on the indicator fish species populations and strengthen and support conservation objectives of the park.

The draft Biodiversity Action Plan (BAP), including a Biodiversity Monitoring and Evaluation Plan (BMEP) will be updated and finalized in the 1Q of 2015 after further consultation with key stakeholders, and include metrics to measure and track abundance/population of these two fish species in the project’s area of influence and to quantitatively evaluate if net gain is achieved for these two species over time.

A basin wide study approach was used for the ESIA of Gulpur HPP therefore 11 rural communities were consulted along the Poonch River. In addition to the potentially affected communities, local government and local NGO officials were also consulted. As part of the updated ESIA process, consultations were undertaken with communities and institutions that may have interest in the proposed project or may be affected by it. Consultations with stakeholders were undertaken during the third and fourth week of February 2014. The main document for distribution to stakeholders during the consultations was the Background Information Document (BID) that informed the stakeholders about the ESIA process and provided a background about the project. The BID was made available in English and Urdu to suit the language preferences of different stakeholders. Separate meetings with institutional stakeholders were arranged in Kotli, Islamabad, and Muzaffarabad.
The updated ESIA and the draft LARP include a grievance mechanism for community members and affected parties. An overall project grievances redress mechanism will be developed whereby project stakeholders will be entitled to lodge complaints regarding any aspect of the project. Complaints will be able to be made verbally or in written form. To allow for grievances to be handled effectively, the client shall establish the following: (i) A Public Complaints Unit (PCU), which will be responsible to receive, log, and resolve complaints; (ii) A Grievance Redress Committee (GRC), responsible to oversee the functioning of the PCU as well as the final non-judicial authority on resolving grievances that cannot be resolved by PCU; and (iii) Grievance Focal Points (GFPs), which will be educated people from each community that can be approached by the community members for their grievances against the Project. The GFPs will be provided training by the Project in facilitating grievance redress. The stakeholders will be informed of the establishment of the PCU through a short and intensive awareness campaign that will share the objective, function and the responsibilities of the PCU; means of accessing the PCU and the mechanics of registering a grievance at the PCU; operating principles of the PCU; and contact details of who to reach and how to reach them in order to file a complaint. A detailed procedure for the functions of the PCU are included in the ESIA and the draft LARP by which the client will be required to adhere to in relation to IFC’s PS 1 requirements for a community grievance mechanism.
Stakeholder engagement and consultation is addressed in several places in project documentation, covering various aspects, but is not incorporated into a single stand-alone Stakeholder Engagement Plan (SEP). MPL will produce and disclose a consolidated SEP consistent with Performance Standard 1 requirements, as outlined in ESAP.
MPL also plans to produce an annual Corporate Social Responsibility (CSR) plan, which will provide detailed information on method, roles and responsibilities of interaction with the local community, mitigation of socio-cultural impacts such as social ills, socio-cultural conflicts and enhancement of positive impacts. It will include the identified environmental and social impacts, their enhancement/mitigation and proposed budget for the implementation of mitigation measures. The mechanism for employment of locals and stakeholder engagement will also be outlined in this plan. The CSR Plan will include maintaining regular communication with local communities and other stakeholders to minimize possible tensions arising from project activities; maintaining a grievance mechanism for the community members; encouraging and facilitating stakeholders to use the mechanism to express concerns; and providing sufficient resources to the community relations team to enable them to monitor negative perceptions and associated tensions, and to address them in a timely fashion.
The annual CSR Plan to be prepared by MPL once operations begin will also include plans for supplementing the existing health care services and facilities for local communities in the project area. A basic clinic and paramedics are proposed to provide primary healthcare services to local people three times a week. In addition, the project will attempt to provide financial and technical assistance on health issues in Kotli and in rural communities in the project influence area to impart training through an experienced NGO, involving preventive measures against water–borne diseases, and mother–and–child care. The project will aim to contribute to local economic activities by supporting skills training and capacity building activities for these poor communities, especially for the women and youth. Vocational training programs will focus in skill development in construction and power industries. There will be a separate, more limited, CSR policy and procedure for the construction phase.
The client will follow the Security and Exchange Commission of Pakistan''s Voluntary CSR guidelines to develop a long term partnership with stakeholders including the local community and will develop the above-mentioned CSR plan in consultation with these stakeholders and the local governorate’s EPA. The estimated CSR budget is 20 million Rupees ($200,000) during the construction period and 3 million Rupees ($30,000) for the operational period per annum. This is based on the Conditional Environmental Approval by the local governorate’s EPA.

For additional information please contact:
Jahanzeb Murad
Manager ESH & CSR
Mira Power Limited
Address: House 10-C, Sumbal Road, F-10/3, Islamabad, Pakistan
mailto:jahanzeb@mira-power.com
Phone: +92 344 9777738
Website: http://www.mira-power.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
The Client will present a Stakeholder Engagement Plan (SEP) consistent with Performance Standard 1 requirements.	03/15/2015
The Client will expand the Cumulative Impact Assessment section within the ESIA into a stand-alone Rapid Cumulative Impact Assessment (RCIA) document, outlining the expected cumulative impacts and risks at the Poonch / Jehlum watershed level, and proposed mitigation measures and necessary institutional arrangement to manage such impacts.	11/15/2014
The Client will develop an overarching Environmental and Social Management System (ESMS) to ensure compliance with the ESIA’s Environmental and Social Management and Monitoring Plan (EMMP), other E&S Plans and Lenders E&S requirements. This ESMS will build on the company’s corporate ESHS policies and procedures and follow good international industry practices (GIIP) and be consistent with the requirements of IFC’s Performance Standard 1; as a minimum it shall include an ESHS Policy, proposed organizational structure, a procedure to identify of ESHS risks and impacts, management programs, an overarching monitoring, reporting and non-compliances tracking mechanism; an emergency preparedness and response plan; and a stakeholder engagement plan. As part of this ESMS, the client is required to: (a) Have a dedicated ESHS & CSR Manager for the project, in charge of customizing the corporate policies and procedure to the project, and managing and supervising project’s compliance with the EMMP, E&S Plans and Lenders E&S requirements, as well as delivering training and preparing periodic ESHS compliance reports. (b) Ensure regular monitoring of construction and commissioning activities will be undertaken against the EMMP, other E&S Plans and Lenders E&S requirements.	03/15/2015
The Client will ensure that the EPC Contractor prepares a Construction Environmental and Social Management Plan (CMP) demonstrating the manner in which it will comply with the requirements of the ESIA’s EMMP, other E&S Plans and Lenders E&S requirements. The CMP will include: a) Company’s ESHS policies and local, WB and IFC requirements; b) details of the existing E&S management plans; c) training plan; and a d) monitoring plan, including site inspections/audits, reporting, record keeping, accident/incident investigation and corrective action, and periodic reporting to management. The monitoring plan will also include details on how the Company will supervise and ensure Construction Contractor’s ESHS compliance, including PS2 issues.	01/15/2015
The Client will develop an Operations environmental and social management plan (OMP), conforming to good international industry practices such as those reflected in IFC’s PSs and World Bank Group applicable EHS Guidelines. The Client must ensure that KOSEP (O&M) will be mobilized to the project site ten months prior to construction completion to ensure smooth transition/taking-over and plant commissioning.	09/15/2018
The EPC Contractor will implement worker camp standards and regulations, including provision of adequate accommodation facilities in all its campsites in accordance with internationally recognized standards (i.e. space standards for dormitories, minimum quantities of sanitary installations, maximum distances to installations, resting area requirements at construction fronts, among other key issues) and defining the code of conduct for workers. The company will adhere to IFC’s Worker’s Accommodation guidelines for construction to be outlined in the Construction Management Plan. http://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustainability/publications/publications_gpn_workers accommodation.	01/15/2015
The EPC will develop an Occupational Health and Safety (OHS) Risks and Management Procedures – either as a stand-alone document or within the Construction Management Plan (CMP). These procedures will identify task-specific OHS risks, define safety protocols to follow for each task, personnel qualification, limitations and equipment needs (e.g. personal protective equipment), training and supervision programs, corrective measures implementation mechanisms, and reporting.	01/15/2015
The Company will develop a OHS Risk and Management Procedure for operations. These procedures will identify task-specific OHS risks, define safety protocols to follow for each task, personnel qualification, limitations and equipment needs (e.g. personal protective equipment), training and supervision programs, corrective measures implementation mechanisms, and reporting.	09/15/2018
The Client will develop a GHG protocol to calculate GHG emissions from the reservoir.	02/15/2019
The Client will develop a detailed Emergency Response Procedure (ERP) including detailed emergency response in the cases of dam breaks, natural disasters, earthquakes, fire / explosion, severe traffic accidents, violence and/or social unrest, hazardous products spills, floods, landslides, fall of people into water channels, and forest fires.	09/15/2018
The Client will perform a Security Risk Assessment (SRA) with a qualified international security risks firm. The SRA will also identify any potential risks that its own and/or government-owned security arrangements may pose to those within and outside the project site, including the residents of the nearest towns.	12/15/2014
Based on the SRA, the Company will present a Security Management Plan (SMP) to assure that employees, sub-contractors, as well as physical assets are safe, under surveillance and in a controlled environment. The SMP will be (a) site specific and comprehensive (b) commensurate to the security risks, (c) describe security risks and detailed response procedures, (d) aligned with the Voluntary Principles on Security and Human Rights (http://www.voluntaryprinciples.org), and (e) assure that all security personnel, but especially those who will bear arms, are trained and operate consistently with such principles. This plan will also include an initial awareness workshop and site briefing for all employees.	01/15/2015
The Client will finalize and disclose an implementable Land Acquisition, Livelihood Restoration and Resettlement Plan (LARP). This includes the implementation of the Land Acquisition and Resettlement Unit (LARU)	12/01/2014
The Client will commission a qualified independent consultant to perform an ex-post Land Acquisition, Livelihood Restoration and Resettlement Completion Audit Report, reflecting full compliance with PS5 and with the LARP objectives, and identify corrective actions if necessary	01/15/2020
The Biodiversity Action Plan (BAP), will be updated after further consultation with key stakeholders, and include: (a) Feasibility Assessment, reflecting the likelihood of the Pro2 scenario to occur, and including a sensitivity analysis (e.g. 50%, 40%, 30% reduction of 2013 non-flow related pressures) (b) Metrics to measure and track abundance/population of Kashmir Catfish and Mahaseer fish in the project’s area of influence and to quantitatively evaluate if net gain is achieved for these two species over time. (c) Biodiversity Monitoring and Evaluation Plan (BMEP) (d) Ecological Flow Management Plan. (e) Detailed Mahaseer Hatchery rehabilitation and restocking program. (f) Proposed road-map for the government to develop a National Park Management Plan.	03/15/2015