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

PS1: Assessment and Management of Environmental and Social Risks and Impacts
PS2: Labor and Working Conditions
PS3: Resource Efficiency and Pollution Prevention
PS4: Community Health, Safety and Security
PS6: Biodiversity Conservation and Sustainable Management of Natural Resources
PS8: Cultural Heritage

All the wind turbines will be located on private farm land leased from individual land owners. In addition, the Project’s substation is also to be located on private land leased from the respective land owner. The transmission line to be constructed by Eskom will also be located on private land. Eskom have acquired a right of way to establish the transmission line and given use of this land by the owners will be curtailed to some extent, Eskom will pay compensation to the applicable land owners. Thus PS5: Land Acquisition and Involuntary Resettlement does not apply to the Project. There are no Indigenous Peoples in the area and thus PS 7: Indigenous Peoples is also not applicable.

This is a is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts that may result from construction and operations can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

A comprehensive EIA has been undertaken for the Project which included a thorough review of social issues. The Project has received all the necessary regulatory approvals and a detailed Environmental Management Plan (“EMP”) has been compiled for the construction, operation and decommissioning phases. During the environmental assessment process there were numerous opportunities for stakeholders to comment on the project and issues and concerns identified have been adequately addressed. Further, there have been no objections to the Project’s Environmental Authorization.

THE PARAGRAPH BELOW IS TO BE INSERTED BELOW BEWTWEEN BETWEEN THE SECTION TITLED “MAIN ENVIRONMENTALAND SOCIAL RISKS…….” AND THE SECTION TITLED “PS1: ASSESSMENT…………”
Amakhala has presented plans to address the potential environmental and social impacts to ensure that the Project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to the company, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and the applicable World Bank Group (“WBG”) Environmental, Health and Safety (“EHS”) Guidelines. Key issues relate to impacts as a result of land clearance during construction and impacts on avifauna during operations. Information about how these potential impacts will be addressed by the Project is summarized in the paragraphs that follow, and in the Project’s Environmental and Social Action Plan (“ESAP”) which is disclosed with this document

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.

Windlab commissioned Savannah Environmental (Pty) Ltd, a locally based experienced consulting company, to undertake an EIA for the full area (270 km2) as initially considered for development of the wind energy facility. The EIA was required in terms of the National Environmental Management Act (“NEMA”) and initiated in early 2010, with completion in 2011. The EIA was subsequently approved with issuance of an Environmental Authorization (“EA”) with associated conditions of approval by the national Department of Environmental Affairs (“DEA”).



Given the subsequent need to have smaller individual projects due to the Government bidding process for renewable projects, Windlab requested the DEA to issue separate EA’s for the 4 respective project phases. Thus phase 1 to which Cennergi had acquired the rights was issued with a separate EA in the name of Amakhala and, in doing so, approval was provided for 66 wind turbines and the associated infrastructure.



The EIA commissioned by Windlab for the broader project was comprehensive and included extensive public consultation throughout the process; national legislative requirements for EIA’s prescribe consultation requirements with non-compliance being grounds for an appeal which could delay or halt a project. In addition, detailed specialist studies were completed by experienced personnel on key issues including ecology, avifauna, noise, aesthetics, cultural heritage, and social issues. Further, there was also an assessment of cumulative impacts taking into account other potential wind projects being considered in the broader region. Independent of the EIA an assessment was also undertaken of transportation and logistics with a focus on the transfer of the turbines to site.



Conditions of approval defined in the EA for the Project required various additional studies and plans to inform the final wind turbine layout and compilation of an Environmental Management Plan (EMP) for the construction and operational phases. More specifically, these conditions resulted in; i) an avifaunal pre-construction monitoring plan including a further one year’s monitoring over and above that undertaken as part of the original EIA; ii) identification of heritage sites; iii) a vegetation and rehabilitation plan; iv) plant rescue and protection plan; v) waste and stormwater management plan; and vi) transport and traffic management plans. Compilation of the EMP has been structured to ensure compliance with the Project’s conditions of approval as defined in the EA.



Although the EIA undertaken by Windlab assessed impacts associated with the transmission line to the Eskom substation, this alignment has since marginally changed. In addition, Eskom will construct and own the transmission line whereas it had been originally proposed that the Amakhala would own the line. Thus Eskom have commissioned Savannah Environmental to undertake the EIA for the transmission line and this is currently underway. Impa
cts of this transmission line have largely been identified in the Windlab EIA which identified no significant issues associated with the activity. Thus no major concerns are predicted for the line and an EA will be issued to Eskom in due course.



In addition to the EA, the Project has also required various other related approvals such as a Water Use License in accordance the National Water Act as required where infrastructure traverses water courses, a transport permit in terms of the national Road Traffic Act to upgrade public roads, civil aviation authority consent in terms of the Aviation Act given the potential risks posed to aviation by the turbines, and land rezoning approvals in terms of the Land Use Planning Ordinance, amongst others. Cennergi has defined a list of all possible approvals / permits to be required for the life of the Project and has a representative dedicated solely to ensure compliance with relevant legislation.



The EMP has sections that deal with emergency response, for example associated with fuel spills and the like, however the approach is ad hoc. Thus Amakhala will compile a consolidated emergency response plan for the Project to address potential incidents during both phases such as traffic accidents, impacts on community members and farm animals, and blade throw.



Hatch Africa (“Hatch”) has been appointed as the project manager on behalf of Amakhala and will act as the owner’s engineer for the construction phase. Where necessary, technical support will also be provided by Cennergi personnel. Thus Hatch and, as required, Cennergi will be responsible for reviewing the EPC contractor’s performance.



As per the EA, a full time independent Environmental Control Officer (“ECO”) will be appointed to monitor implementation of the EMP. The ECO will have the authority to stop the work of any contractor or service provider found violating the prescriptions of the EMP and Environmental Authorization. The ECO will compile regular performance reports, which may include corrective actions, for submission to Hatch, Cennergi and the DEA. Hatch will also have an individual responsible for overseeing environmental performance of the contractor and compliance with the EMP. In addition, Amakhala will be required to confirm the Project’s compliance with the EMP and EA conditions of approval as part of its annual environment and social reporting requirements to IFC.

Currently Cennergi have professional staff in their employ who provide services to the Project / Amakhala. While this still needs to be defined, it is likely to continue until the operational phase when the maintenance and operational staff will be in the direct employ of Amakhala. Cennergi have a Human Resources (“HR”) Manager who ensures compliance with all Cennergi’s projects with applicable South African legislation. In addition, the company has an Environmental, Health, Safety (“HSE”) Manager whose tasks include overseeing Cennergi’s projects to ensure compliance with legislative requirements.



The EPC Contractor will be responsible for employing all workers during the construction phase. Construction activities will generate short-term employment for up to 100 people at the peak of construction. It is estimated that some 60% of this labor will be sourced from the local communities. During operations a compliment of approximately 10-15 staff will be required.



No accommodation will be provided in the Project area for construction personnel, or those associated with operations. As necessary, accommodation will be acquired in the nearby towns of Bedford and Cookhouse.



Compliance with South African labor legislation would ensure alignment with this Performance Standard including that associated with OHS. Amakhala will contractually require the EPC contractor to comply with South African labor legislation. In addition, Amakhala, either internally or via the EPC contractor, will prepare and implement a site specific HSE plan for the Project’s construction phase.



Amakhala will also develop a Human Resources (“HR”) Policy and management system consistent with South African labor laws and the requirements of Performance Standard 2 for its operational personnel. At a minimum, each employee must have a contract and understand his/her rights related to hours of work, wages, overtime, compensation and benefits on commencement of employment and when any material change to that employment occurs. In addition, either together or separate from the HR policy, Amakhala will declare a commitment against the use of forced labor or harmful child labor, and must not seek to influence or prevent any workers from organizing or seeking collective bargaining rights. The HR policy must reflect a commitment to make employment decisions based on inherent job requirements, non-discrimination and equal opportunity. In addition, Amakhala will need to establish a grievance redress mechanism and disseminate information on how workers’ take advantage of that mechanism among the Project workforce.

Potential pollution issues during the construction phase are those typically associated with construction sites and include, amongst others, the discharge of contaminated (high silt loads / oil and grease) stormwater and diesel and oil spills. In addition, there is the potential for nuisance impacts (e.g., noise and dust,) to the landowners and their employees. The EMP has detailed mitigation measures for potential pollution issues during construction including a stormwater and waste management plan, soil erosion management plan, requirements associated with the storage of hazardous materials e.g., bunding of fuel tanks. In addition, should such issues impact on communities or the famers, there is a grievance mechanism whereby these can be addressed.



Potential pollution issues during the operational phase are limited and the EMP equally makes provision for mitigation measures such as requirements for the storage of hazardous materials, and the disposal of wastes.



Noise impacts during the Project’s operational phase were identified as having a low significance and all of the turbines will be located at least 1 km from any potential receptor. Given the proximity of the turbines to receptors and the sparsely populated nature of the region, wind flicker was not considered as an impact.



Based on a generation capacity of 138 MW and assuming the energy source substitutes energy as produced by Eskom which is largely coal based, the Project would result in a saving of 347,000 tons CO2 generated. Cennergi will manage all greenhouse gas (“GHG”) reporting requirements as required and detailed under the ISO 14064 and the Amakhala greenhouse gas protocol.



A visual impact assessment was undertaken as part of the EIA with potential impacts on homesteads within a 5 km radius being defined as high. Impacts on communities in the area such as those residing in the nearest towns of Bedford and Cookhouse were considered as low given their distance from the Project. In considering this impact though it must be acknowledged that the visual assessment was for the larger Windlab project which included 350 turbines; the Project only includes 66 turbines. Nonetheless, the assessment is effective in that it provides for a cumulative assessment of visual impacts. In addition, it takes into account the potential for other wind facility projects in the area i.e., other than that associated with Windlab. Given the low incidence of visual receptors in the area and the contained nature of the visual exposure, the assessment notes the impact is not a fatal flaw.

The turbines will be located on private farming land which is primarily used for sheep farming and the total area is 130 km2 on which only 66 turbines will be located. In addition, the closest communities are located in the towns of Bedford and Cookhouse which are in excess of 15 km from the Facility. Thus potential direct impacts on communities as a result of site based construction activities are considered limited. However as per the EMP, construction areas will be fenced with access limited to construction personnel.



There will also be an emergency response plan in the event of an incident and security will be provided by unarmed security personnel who are able to call on the local police if required.



The primary impact on communities will be as a result of traffic. The turbines will be imported via the Port Elizabeth harbor which is some 150 km from the site and then transported to the Project area by road. The road to the area is generally in a good condition, though some sections will need to be upgraded as identified in the transport and logistics study. Based on this study which included a survey of the entire route to the Project site, a traffic and transportation plan has been compiled for inclusion in the EMP. This plan defines the approach to all transport associated with the Project and implementation thereof will be monitored by the ECO and Hatch. In addition, transportation of the turbines to the site will need to comply with relevant legislation including the need to apply defined speed limits and assigning support vehicles to each heavy load.

The EIA undertaken for the full 273 km2 included an ecological study that focused on fauna and avifauna (birds). Key findings of the faunal study include; there is only one plant specifies of conservation concern that is likely to occur on the site, it is not considered likely that any protected tree species occur on the site, construction of infrastructure may lead to a direct loss of indigenous vegetation; construction could lead to a loss of or damage to seasonal wetlands or drainage lines, and a change in runoff and drainage patterns and thus impact vegetation and; the site does not harbor alien plants in any significant densities though project activities would increase the spread of alien species. Based on the mitigation measures proposed and as defined in the EMP and include, amongst others, an ecological survey, a plant rescue and protection plan and rehabilitation plan, the impact on fauna is considered to be low.



The impact on avifauna is defined as moderate in the EIA while noting this study was for the larger Windlab facility. Subsequent to this study, a further avifaunal study focusing specifically on the Project was undertaken and included one year’s monitoring data. Overall the findings from the latter study concur with the study included in the EIA and note that the findings are largely favorable for development of the Project and there is no need to change the turbine layout as originally proposed.



The Project area does not impinge significantly on any unique landscape features, or on any

known, important bird fly-ways, though it is acknowledged that it is likely to affect populations of regionally or nationally threatened which may occur within or close to the Project. Further, these impacts will be detrimental unless mitigation measures are implemented. General estimates of annual turbine collision rates for the Project propose 250 birds overall, 65 casualties of priority species, and 20 Blue Cranes. 

Mitigation measures to be implemented include scheduling activities around avian breeding and movement schedules, limiting land clearance, removing dead stock as soon as possible, installing bird flight diverters on the transmission line and implementing a bird monitoring program (this has been compiled and included in the EMP), amongst others.



Subsequent to completion of the EIA, Windlab commissioned a preliminary impact assessment and sensitivity report associated with the impact on bats. This study included 9 months (December 2011-September 2012) monitoring data and assessed impacts on roosting, fatalities due collisions with the turbines, and fragmentation of the landscape as a result of the development. Overall the impacts were defined as being of low significance assuming implementation of mitigation measures. The latter include ensuring appropriate spacing between the turbines and implementation of an adaptive management strategy inclusive of ongoing monitoring.

A specialist study on cultural heritage was included in the EIA. The findings indicate that pre-colonial archaeology from the Holocene and Pleistocene periods occur in the area and there are historical features, buildings and graveyards associated with the farms. Given the limited footprint of the development and taking into account mitigation measures, the significance of impacts on cultural artifacts in the Project area are defined as low. Subsequent to the study, a detailed heritage survey has been undertaken of the Project area to identify cultural heritage artifacts on the sites so as to inform the EMP. Should artifacts be encountered during construction, the chance find protocol as defined in the EMP will be implemented.

There has been extensive consultation on the Project via the EIA process and this included one-on-one meetings, focus group meetings and public meetings. Equally, to ensure stakeholders were aware of the EIA and associated development under consideration, numerous notices were placed at strategic locations accessed by the public. Following the positive EA for the full development as proposed by Windlab and the subsequent EA issued for the Amakhala project, all stakeholders associated with the Project were notified of an opportunity to a appeal the decision by the DEA, however no appeals were received.

Two community trusts, the Bedford Community Trust and the Cookhouse Community Trust, have been allocated 2.5% of the Project respectively. Both of these trusts have elected members who are represented on the Amakhala Board. Dividends generated by the Trust’s shareholding in the Project will be used to provide socio-economic developments in the area such as the construction of schools and clinics; decisions regarding the developments will be made by the broader Amakhala Board. In addition and in accordance with the requirements as defined by Government for projects associated with the renewable energy program, 1.5% of the income generated by the Project must be allocated to socio-economic development projects. Equally, 0.6% of the income generated by the Project has to be allocated to establishment of small businesses and associated training requirements.
To ensure ongoing consultation during the construction and operational phases and a clear approach to such, Amakhala will compile a Stakeholder Engagement Plan for the respective project phases which will include the grievance procedure as already compiled for purposes of the EMP.

This Environmental and Social Review Summary document and companion ESAP will be disclosed on the World Bank Infoshop.

Amakhala Emoyeni RE Project 1
Wendy Green
Block A, Ground Floor
Lakefield Office Park
272 West Avenue
Centurion
0157
Tel: +27 (0) 12 675 6655
Fax: +27 (0) 12 675 6660
Email: mailto:wendy.green@cennergi.com

Broad Community Support is not applicable for this project

Action	Timetable
Performance Standard 1: Social and Environmental Assessment and Management System
Develop and implement and emergency response	Prior to construction
Develop and implement a Stakeholder Engagement Plan (“SEP”) for the construction and operational phases.	Prior to construction.
Performance Standard 2: Labor and Working Conditions
Confirm compliance of EPC Contractor with South Africa labor legislation including occupational health and safety (“OHS”).	Prior to construction
Develop and implement human resources documentation aligned with South African labor legislation and Performance Standard 2: Labor and Working Conditions for the operational phase including that related to OHS.	Prior to operations