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.

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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

The Project site (1,553 acres) is in a semi desert area and mostly barren land with sparse vegetation. There are two small communities within the Project site, and the Project is being designed to minimize impacts (noise, shadow flicker, disturbance by migration of workers and land use change) on those communities. No physical or economic displacement of people will be required, no cultural heritage has been identified on site and no Indigenous Peoples will be affected. The nearest protected lake (Keenjhar Lake Wild Sanctuary) is 15 km from the Project site, providing sufficient distance to minimize impacts on birds. No major E&S risks are expected from the associated access road or transmission line connection. The Company retained an internationally recognized environmental consulting firm to update the Initial Environmental Examination of 2009 (2013 IEE Update) and to propose measures for the Project to comply with the 2012 IFC Performance Standards. The Company obtained an environmental approval from Sindh Environmental Protection Agency. To date, no major objection has been raised. All considered, the proposed investment in the Project is a Category B project because of a limited number of specific environmental and social impacts may result, but they can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

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.

Policy:

As per MPCL’s Code of Business Conduct and Ethics, the Company is committed to conducting its business in compliance with all applicable environmental and workplace health and safety laws and regulations and MPCL Social, Environmental, Health & Safety (SEHS) Policy (Draft, April 2013). This policy clearly states that the Company will conduct operations in compliance to the applicable laws, regulations and international guidelines and best practices in order to meet social and environmental contractual obligations to investors, lenders, customers and other relevant stakeholders. The SEHS Policy will be signed by the CEO of the Company and will be displaced at the corporate office, the Project operation site, and at the website of the Company. The SEHS performance of the Company will be managed by EHS Manager at the corporate level.



Identification of Risks and Impacts:

In 2009, the Company conducted an Initial Environmental Examination (2009 IEE) and obtained an environmental approval from the Sindh Environmental Protection Agency. In late 2012, the Sponsors retained an international environmental consulting firm (ERM) to review and update the 2009 IEE and to evaluate the Project’s compliance with the 2012 IFC Performance Standards on Environmental and Social Sustainability. The 2013 IEE Update was prepared with an updated E&S assessment.



Although the entire Project site of 1,553 acres has been leased to the Company by AEDB, the Company is aware that there are two small communities within the leased land (Bacho Jhakro settlement, and Qasim Burfat settlement, in total about 36 households). The Company is designing the wind farm layout to minimize impacts on those two communities. The total footprint of the Project is estimated to be less than 80 acres (i.e. wind turbine generators 2.5 acres/WTG x 20 WTGs, access road of about 17.5 acres, and a switchyard of about 5 to 10 acres) compared with the total 1,553 acres of the site. No physical or economic displacement of people is expected. Only the WTGs land parcels and the Project’s substation land parcel will get fenced by the Company for safety and security reasons. The majority of the Project site of 1,553 acres will remain free for access to villagers, and therefore, the impacts would be minor.



The 2013 IEE Update assessed the Project’s impacts in various relevant areas including land use change, landscape and visual impacts, soil environment, water environment, air quality, noise, loss of natural vegetation, loss and disturbance of habitat, disturbance to birds and birds collision risk, settlement and community access, land-based livelihoods, social and demographic structure impacts by influx of workers, local economy and employment, cultural environment, community health and safety including shadow flicker, blade glint, and blade throw. Cumulative impacts were also assessed for the Project and other wind farm projects in the vicinity covering visual impacts, shado
w flicker, noise, birds and bat collision and social aspects.



As noted above, no cultural heritage was identified within the Project site. The Company will establish a chance find procedure and require the EPC contractor to follow this procedure.



Management Programs:

For each of the E&S impacts assessed, the 2013 IEE Update proposed measures to mitigate adverse impacts and to enhance positive ones. A consolidated list of mitigation measures and commitments was compiled as an Environmental and Social Management Plan (ESMP) and included in the 2013 IEE Update. The ESMP sets out the arrangements that will be put in place by the Company to manage the E&S performance of the Project, to outline further studies and surveys to redefine predicted impacts and design appropriate mitigation strategies, to describe the monitoring programs to assess actual impacts and adequacy of mitigation strategies, and to provide framework for compliance auditing and inspection of the Project by the Company.



Organizational Capacity and Competency:

One of the Sponsors, Infraco Asia Keenjhar Wind Pte Ltd, is a subsidiary of InfraCo Asia Development Private Limited, which is owned and financed by the multilateral development organization Private Infrastructure Development Group, a coalition of donors and DFIs including World Bank Group. InfraCo Asia Development Pte Ltd Operating Policies and Procedures require compliance with WB E&S standards, and Infraco Asia Keenjhar Wind Pte Ltd is providing technical expertise and managerial support to the Project’s compliance with IFC E&S standards. Another Sponsor, Iqbal Alimohamed & Family, has experience in working with IFC through Gul Ahmed Energy (#4998) project, and is contributing local E&S expertise, including Corporate Social Responsibility activities to provide benefits to communities affected.



The Project will be constructed under Engineering, Procurement and Construction (EPC) contract with a group of Nordex and Descon companies (in total five companies). The Operation and Maintenance (O&M) of the plant will be carried under the O&M service and supply contract with Nordex Singapore Service Private Limited and Descon Engineering Limited.



During the construction phase, the EHS Manager of the Company will manage all EHS issues and coordinate with the EHS team of EPC Contractor for management of impacts and implementation of ESMP. Social issue will be looked after by the Company’s Community Relations Officer, who will report to the EHS Manager. During the operational phase, the EHS Manager will be part of the Company’s Engineering Department and will work in close coordination with O&M Contractors and the Company’s site employees for management of impacts and implementation of ESMP.



Emergency Preparedness and Response:

The 2013 IEE Update included Emergency Response and Preparedness Plan setting out procedures and measures to be taken to deal with emergency situations including emergency escape,
shutdown during emergency evacuation, accounting for all personnel after an evacuation, rescue and medical duties for employees, and other emergency reporting (e.g. fires, medical emergencies). The Company will make the plan familiar with all employees of the Company, contractors and surrounding villages in close vicinity. The plan will be reviewed and amended when needed to ensure that all parties concerned are furnished with up-to-date information.



Monitoring and Review:

The Company’s EHS Manager, together with the E&S team s of EPC and O&M contractors, will monitor the E&S performance of the Project, including the implementation status of the ESMP. The EHS Manager will also handle regular reporting requirements to regulatory bodies such as SEPA, and to lenders including IFC.

Working Conditions and Management of Worker Relationship:

The Company has established Employees Relation Rules which include the Company’s human resources policy, employment procedures, communications, working conditions, compensation, which are in general, in line with Pakistan’s labor regulations and IFC Performance Standard 2 requirements. It is estimated that direct manpower required during the construction phase will be about 600 workers. In addition, about 100 support staff will be present on site including technical, administrative and security staff. During operation, the Operation & Maintenance (O&M) contract estimates about 28 employees in operations and about 20 to 25 people in security (as contract workers). As part of the 2013 IEE Update, a Construction Labor Management Plan Framework was prepared to assist the Company in managing any adverse impacts on employee during the construction phase. The framework provides key elements for the Company to manage construction labor including resource requirements, workers accommodation facilities, recommended measures, and monitoring and inspection of the workers accommodation facilities. The accommodation facilities will be located within the Project site and far from any settlements. The size of the accommodation facilities will be designed based on the final EPC and O&M arrangements.



Protecting the Work Force:

The Company will not use child labor or forced labor, and will require the same to the EPC Contractor and O&M Contractor.



Occupational Health and Safety:

The Company has a Health & Safety Management Plan Framework prepared as part of the 2013 IEE Update. This addresses the Company’s tasks to coordinate with the EPC and O&M contractors to manage occupational health and safety performance. The Company will require the EPC Contractor to carry out a Health Risk Assessment of all construction activities for all hazards associated with work at the WTGs construction site and associated activities. EPC and O&M contractors will be required to manage each of the key potential hazards by identifying risks, providing training, establishing procedures and monitoring. Key potential hazards addressed in the framework include chemical hazards, physical hazards, noise, vibration, biological hazards, malaria, pest and insect control, ergonomic hazards, working hours and working cycles, fitness to work, and work at height. An ambulance will be provided on site for emergency needs. Contractors’ staff will be trained in the nature of the health hazards and specified controls.

Resource Efficiency:

According to the CDM Project Design Document prepared by the Company and UPM Umwelt-Project-Management GmbH, and submitted to UNFCC in 2012, the Project is estimated to generate 155,500 MWh per year, with greenhouse gas emission reductions of 92,533 tCO2 equivalent per year (assuming the grid emission factor of 0.5952 tCO2e/MWh).



About 1 to 1.5 m3 per day of water will be required during the operational phase of the Project. Considering the general scarcity of water in the region, the Company is planning to adopt water conservation measures including using recycled water as much as possible.



Pollution Prevention:

The 2013 IEE Update predicted that during night time when the wind speed exceeds 6m/s, one of the settlements in the Project site may have slightly higher noise levels (46 to 47.6 dBA) than the World Bank Group (WBG) General Environmental Health & Safety (EHS) Guidelines limit for ambient noise of 45 dBA. To mitigate this predicted impact, the Company will implement the following measures: installation of acoustic enclosures for equipment casing radiating noise, regular maintenance of WTGs, periodic monitoring of noise near the receptor to ensure compliance with SEPA and WBG General EHS Guidelines limits, and incase the measured noise level during operations period is higher than WBG General EHS Guidelines limits and complains of higher noise level from nearby settlements, then the Company will undertake planting of trees between the WTGs and the nearest settlement and/or putting noise barriers near to the receptor as needed. Cumulative noise impacts were assessed for the Project and the Sponsor’s another adjacent project (Gul Ahemed Wind Power Ltd) and are predicted within the WBG General EHS Guidelines limit for ambient noise of 45 dBA except for one of the settlements in the Project site that may have slightly higher noise levels (46 to 47.6 dBA) as mentioned above for which the mitigation is planned as describe above.



On shadow flicker, the 2013 IEE Update predicted that some houses may have shadow flicker impacts of about 14 to 60 hours per year during early morning (5am to 6:30am), and for some houses (16 houses), the impact will exceed the ERM recommended criteria of 30 hours per year. This was based on worst case scenarios assuming optimal meteorological and geometrical conditions for the generation of shadow flicker. The Company plans to conduct a detailed monitoring of actual shadow flicker impacts, and to provide additional mitigation measures as necessary such as providing barriers or blinds. No cumulative shadow flicker impact is expected.



During the operational phase, two small capacity (200KVA and 100 KVA) diesel generators will be installed for emergency power supply, to be operated only as back-up. Fuel will be unloaded in designated areas and stored in above ground storage tank (1,800 liters capacity). A small quantity of oil/oily water may be generated during the mai
ntenance of pumping stations. This will be treated in oil/water separators.

Community Health and Safety:

The Company’s Health & Safety Management Framework sets out measures to ensure community health and safety. Key measures include cordoning off the construction site from free public access, implementing mitigation measures for transporting WTG parts and other materials, transmission line construction to prevent community health and safety (H&S) risks, placing information boards about public safety hazards and emergency contact information in the Project area in the local language, ensuring that construction phase workers are housed in labor accommodation facilities built at least 1km from any communities, providing H&S training to raise awareness about STDs and HIV, and maintaining worker behavior standards. To ensure traffic safety in the local communities, the Company will require each contractor to ensure communities are advised in advance of project progress and near term activities where transport issues have the potential to impact local communities. Special attention will be given to any local religious fairs, market days or during movements associated with village processions.



Security Personnel:

About 20 to 23 armed security staff will be working during the operational phase of the Project mobilized by the O&M contractor. The Company will ensure that necessary trainings will be provided to the security staff about the appropriate use of force where applicable and appropriate conduct toward workers and affected communities in line with IFC Performance Standard 4.

No wildlife reserves are located near the Project site. Keenjhar Lake Wildlife Sanctuary, a designated Ramsar wetland and Important Bird Area, is located 15km from the Project site, which is considered to be sufficient distance to minimize potential negative impacts on migratory birds. However, the baseline study of birds of the 2013 IEE Update, which was conducted mostly by desktop research and supplemented by additional field survey in early 2013 describes that 59 species of birds were reported in the wind farm area and its surrounding. Out of the 59 species reported, the Saker Falcon was listed as Endangered as per the IUCN category, Imperial eagle was listed as Vulnerable, and the Long tailed Bush Warbler and Kashmir Roller were listed as Near Threatened.



The Company will implement the following mitigation measures: (i) all WTGs to be erected at a distance of more than 400m to reduce the risk of avian collision and to give the birds a wider corridor for the access in the Project area; (ii) the WTG towers will be identical thus increasing visibility for the birds; (iii) internal electricity lines from each WTG to the Project substation will be underground thus reducing collision chances; (iv) use of flash lamps on the WTGs to prevent bird collision at night; (v) regular checking of the vacuums or holes in the towers to reduce the risk of birds nesting in the WTGs; (vi) bird mortality count in the immediate vicinity to establish any link between the wind turbines and birds mortality for two years starting from the commissioning of the wind farm.



To assess the exact impact of the WTGs on the birds in the Project area, and to evaluate the effectiveness of the mitigation measures, the Company will appoint a local bird expert to conduct bird monitoring study. The bird monitoring study is proposed to include (Annex I of the 2013 IEE Update): collection of bird observation samples using linear (or strip) samples (three linear samples of 50 meters width and 2,000 meters length to conduct regular observations of birds throughout the year); and point samples (three point samples at three vantage points for the observations of the flying birds over the turbines). Vantage points will help in noting the flocks of migratory birds and local birds over the turbine towers. In addition, two additional linear samples will be conducted to search for bird carcasses in the early mornings on alternate days during migration seasons (spring and autumn days). Details of the bird monitoring program (methodology, frequency and duration) will be determined in consultation with the bird expert. Further mitigation measures will be proposed based on the outcome of the monitoring program.

Since 2009 the Company has been consulting key stakeholders including (i) institutional stakeholders (District administration in Thatta and regulatory bodies such as the AEDB and the Sindh EPA authorities) and (ii) local communities including the two small communities (Bacho Jakro Goth, Qasim Burfat Goth) within the Project site, and other settlements in close proximity to the Project. Formal stakeholder consultation has been carried out in two phases: Phase I for the preparation of the 2009 IEE (in April 2009 at Qasim Burfat Goth, Janoo Burfat Goth, Jakhro Jamali, Brohi Goth), and Phase II for the preparation of the 2013 IEE Update (in February to March 2013 at Qasim Burfat Goth, Janoo Jakhro Goth, Bacho Jakhro Goth, Haji Wallo Jakhro Goth, Murad Ali Chang Goth, Janoo Burfat Goth, Vakhio Jakho Goth). In both phases, the Company provided available information on the Project, including proposed design, and facilitated informed consultation on community needs, concerns and expectations. In order to account for any changes in the Project specification, as well as details of impacts associated with livelihoods, environmental parameters and community health and safety, the Company will conduct general stakeholder meetings to disclose the findings of the 2013 IEE Update. The locations of the meetings are still to be finalized, but will include the key villages (or Goth) listed above.
Consultations so far held highlighted resettlement and health & safety concerns among people residing within the two communities on the land leased by the Company. In addition, people are also aware of certain precedents on land compensation and employment being offered by other wind energy projects in the vicinity. The 2013 IEE Update explains that there is a sense of uneasiness among locals who do not have any formal or documented land title rights but believe the land belongs to them by virtue of traditional rights, and that the government may take these lands at any time for development projects or industries. As noted earlier in this review, the Company will not relocate the two communities living on the Project land and is designing the Project to minimize impacts on them, to implement necessary mitigation measures to address their concerns, and to provide community support programs. For example, the Company has collaborated with other wind energy developers in the project vicinity to engage with village settlements in providing support for drinking water needs, local institutions and sanitation. The Company has also engaged local personnel for security, guarding the wind masts and other jobs at site. Employment was provided subsequent to discussion with village elders in order to make the process transparent and consultative. Strengthened community support programs are also being developed by the Company.

Danish Iqbal
Chief Executive Officer
Metro Power Company Ltd
36-F, Block-6, P.E.C.H.S,
Karachi, 75400, Pakistan
Phone: +92-21-4540270-3
Fax: +92-21-4540274
Email: mailto:danish.iqbal@metro-group.com.pk

The following documents are also being attached to this ESRS:
50 MW Wind Power Plant by Metro Power Company Limited: Jhimpir, Pakistan, Non-Technical Summary, Prepared by ERM, July 2013
50 MW Wind Power Plant by Metro Power Company Limited: Jhimpir, Pakistan, Initial Environmental Examination Update, Prepared by ERM, July 2013. This includes (i) Environmental and Social Management Plan (Section 8.5), (ii) Stakeholder Engagement Plan Framework, Construction Labor Management Plan Framework, Emergency Response and Preparedness Plan, Health and Safety Plan Framework (in Annex L).

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Hold a general stakeholder meeting to disclose the findings of the 2013 IEE Update.	12/31/2013 12:00:00 AM	Completed	Completed	06/18/2014 12:00:00 AM
Develop Stakeholder Engagement Plan based on the Stakeholder Engagement Plan Framework included in the 2013 IEE Update.	12/31/2013 12:00:00 AM	Completed	Completed	08/13/2014 12:00:00 AM